When it's used
After meet-and-confer fails, within 45 days of the initial deficient response being served.
Definition
A Motion to Compel Further Responses is filed under California CCP §2030.300 (for interrogatories) or the parallel statutes for RFPs and RFAs when a party’s discovery responses are incomplete, evasive, or improperly objected to and informal resolution has failed. The motion must be filed within 45 days of service of the deficient responses or the court loses jurisdiction to hear it, making deadline tracking a critical paralegal responsibility. The paralegal prepares the notice of motion, separate statement (setting out each disputed request, the response, and the argument for why further response is required), supporting declaration, memorandum of points and authorities, and proposed order. A well-organized separate statement is the heart of the motion and must clearly demonstrate, request by request, how each response falls short of the responding party’s statutory obligations.