Sample motion to compel further responses to interrogatories in United States District Court

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This sample motion to compel further responses to interrogatories in United States District Court is designed to compel further responses to interrogatories on the grounds that the other party has failed to provide any meaningful responses to written interrogatories, or has interposed boilerplate objections.  The sample motion is filed under Federal Rule of Civil Procedure 37 and requests sanctions on the grounds that the other party has failed to respond to written interrogatories despite a good faith effort to meet and confer.  The sample is 15 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service. The author is an entrepreneur and freelance paralegal that has worked in California and Federal litigation since 1995 and has created over 300 sample legal documents for sale. Note that the author is NOT an attorney and no guarantee or warranty is provided.