Sample Motion to Compel Further Responses to Special Interrogatories for California

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This sample motion to compel further responses to special interrogatories for California is for use by a party who wants the Court to compel the other party to provide further responses to special interrogatories. The sample motion has been revised and updated in March 2018, is over 30 pages and includes a request for sanctions, memorandum of points and authorities with citations to case law and statutory authority, separate statement, sample declaration and proof of service by mail. The motion can also be modified to use to compel further responses to form interrogatories. The author is a freelance paralegal that has worked in California and Federal litigation since 1995 and has used this sample for many years. Note that the author is NOT an attorney and no guarantee or warranty is provided.