Sample Motion to Compel Responses to Requests for Production of Documents in California

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This sample motion to compel responses to requests for production of documents in California is used when a party has served requests for production of documents but has received no responses. The motion contains a memorandum of points and authorities with citations to case law and statutory authority, a sample declaration and proof of service by mail. 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.