Motion to compel production of documents

Motion to compel production of documents. [Doc. 1345. CCP § 2025. 240). : 35 All Documents relating to the source code, object code, HTML and other computer code for all computer programs identified in MP Exh. In this scenario, the requesting party may file a motion to compel, seeking court intervention to enforce the production of the requested documents. R. The Grande Holdings Limited (2011) 198 Cal. If no responses at all are served, there is no time limit on when Motion To Withdraw. While typically filed with respect to discovery responses in civil litigation, they may also be filed for other reasons such as to compel compliance with a prior court order. 310 (requests for production), and 2033. . Motions to compel discovery. . 37 (b), upon which it was patterned. Subsection (4) provides: Award of Expenses of Motion. 1 (a), (b), (c) the motion should include the following: Facts concerning all prior requests, including dates propounded, responses received, etc. 300. 224 pages. Noncompliance with document production: Imagine a civil lawsuit in which one party seeks specific documents as evidence but the opposing party is uncooperative and fails to produce them. 2d 443 [1965]; Mihaly v. CCP §§ 2030. UAWARD OF EXPENSES AND FEES ON MOTION TO COMPEL U: A motion under Fla. 792 (1974), states in pertinent part: “Any party may serve on any other party a request (1) to produce and permit the party making the request . 35. For example, in a personal injury lawsuit, the person who has been sued, the On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause. A party, upon reasonable notice to other parties and all persons affected thereby, may apply for an order compelling discovery as follows: (1) APPROPRIATE COURT. a request for extension has not been filed, and. Ct. 310 provides: Jan 28, 2020 · A motion to compel asks the court to enforce a request for information relevant to a case. For purposes of this paragraph, a statement previously made is a written statement signed or otherwise adopted or approved by the person making it, or a stenographic, mechanical, electrical, or other recording or transcription of it that (b) Motions to compel. 2 pages. See Court Opinions . Eliot, Esq. Plaintiff’s counsel will file unredacted copies of these documents under seal within 14 days of this Order. 3. Oct 19, 2019 · A motion to compel is a document filed in a court proceeding asking the judge to force the other party to do something. 300(c), 2031. (In re United Fire Lloyds (2019) 578 Jan 1, 2023 · California Code, Code of Civil Procedure - CCP § 2031. BOX 2131 SANTA MONICA, CALIFORNIA 90407-2131 ELECTRONICALLY FILED TEL. Jul 18, 2017 · PHARMERICA’S MOTION TO COMPEL AND (2) HOLDING IN ABEYANCE POTENTIAL SANCTIONS . This is comprised of an hourly rate of $400 multiplied by 6 hours (4 for drafting the motion and 2 for meet and confer efforts), plus the $60 filing fee. It should be noted that in Respondents’ requests for production, Respondents ask Complaint Counsel to produce documents dating beyond the date of the Complaint, up to the date of the request. 3d 681 at 685 (Pre / RECEIVER'S MOTION TO COMPEL PRODUCTION OF DOCUMENTS IN COMPLIANCE WITH NON-PARTY SUBPOENA Pursuant to Rule 45, Federal Rules of Civil Procedure, Burton W. Wiand, as Receiver, respectfully moves (the "Motion") the Court for an order compelling the production of documents subpoenaed from Managed Capital, LLC ("Managed Capital") and to award the Nov 26, 2023 · Ask the court clerk about the method used in your court. , Laura G. Aug 2, 2018 · When Is a Motion to Compel Used. 310(c) and 2032. 01. ) 3124 in a New York state court litigation. 9 IV. [SBN 155876] 2 TRACHTMAN When a motion to compel discovery is filed in accordance with Rule of Civil Procedure 1. to question. While courts and practitioners sometimes refer to the defendant’s receipt of materials from both the prosecutor and nonparties as “discovery,” this imprecise use of the term confuses a defendant’s right to discovery from the prosecutor with a Mar 28, 2017 · Pending before the Court are two discovery motions, plaintiffs‟ motion to compel related to the Rule 30(b)(6) deposition testimony of KMC [Doc. 1(b). THE ALTERNATIVE, FOR AN IN CAMERA INSPECTION OF DOCUMENTS. Request made to a court asking for permission to retract or "withdraw" a step that a party or lawyer has taken in an existing lawsuit, such as resigning as attorney of record or removing a lawsuit from the court's docket. - It is . (A) Any party, upon reasonable notice to all other parties and any persons affected thereby, may move for an order compelling discovery, with respect to: (1) Any failure of a party to answer an interrogatory served under rule 4901-1-19 of the Motion to Compel Further Responses If the meet and confer process does not result in a full resolution of the dispute, then a propounding party’s final recourse is to file a motion to compel further responses. If you chose option three, then you must prepare a privilege log. Mar 26, 2024 · Unless required by the court, a party shall not file any of the documents or things produced with the response. In a limited civil case (cases less than $25,000, or $35,000 if filed after Jan. Jan 1, 2023 · California Code, Code of Civil Procedure - CCP § 2031. Microsoft Corp. Moxy Power Systems, I…. Discovery requests: parties submit requests for evidence, documents, and The Connecticut Supreme Court has noted that “ [a] subpoena is an appropriate process for the production of documents that are relevant to the matter before the court. 1987]. D. The amendment's purpose is to increase compliance with discovery orders, by making it easier for parties to achieve, and judges to award, sanctions for the failure to comply with a discovery order. Rule 34(c) was also amended to add a cross-reference to Rule 45 (Rule 34(c)(2)). Respondent filed an opposition to the Motion on December 19, 2022 (“Opposition”). Documents or things may be filed in compliance with Florida Rule of General Practice and Judicial Administration 2. By and through his attorney, Corey R. C. FAILURE TO MAKE OR COOPERATE IN DISCOVERY: SANCTIONS. 010) against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel an answer or production, unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the A motion to compel is a legal request asking a court to require a party to comply with a discovery request. Here is a general sequence of events leading up to the filing of a motion to compel: The lawsuit officially begins when the Plaintiff initiates a civil action against the Defendant. The notice of motion should specify the code sections authorizing a motion to compel and sanctions for each discovery tool. – Defendants, CASE NO. 300 (interrogatories), 2031. 39) is GRANTED in that Plaintiff shall have up to and including June 26, 2017 to respond to Defendant’s [sic] First Request for Production of Documents and Things (Doc. 24-C-04-008432 MT. If a party fails to comply with a discovery request, the other party may be at a disadvantage in preparing their case. You can typically serve notice by sending a copy of the motion and any notice of hearing to the other side’s lawyer. The response must contain adequate justification for that party’s objections, or argument showing why the party’s answers to the discovery requests at issue were sufficient. which constitute or The party who files a Motion to Compel is called the “moving party” and he or she may file a Motion to Compel when another party or non-party has provided an inadequate response to a discovery request pursuant to the Federal Rules of Civil Procedure. 39 at 4-7). 220); (2) state that after a diligent search and a reasonable inquiry you have no documents (C. ALBRITTON respectfully prays that Cisco's Motion to Compel Production of Documents be, in all respects, DENIED, and for such other and further relief to which he may be entitled. A motion to compel is a request for an opposing party to produce certain information, typically information that was previously requested during the discovery process of a case. If the motion is granted and after opportunity for hearing, the court shall require A motion to compel answers to deposition questions or the production of documents or things must be made no later than 60 days after the completion of the deposition record. Pursuant to M. 2d 791 [3rd Dept. This is the most common discovery motion we file. 060. (310) 576-1200 Superior Court of Califo…. ” (See I. motion to compel disclosure. A motion to compel answers to deposition questions or the production of documents or things must be made no later than 60 days after the completion of the deposition record. Send a copy of the motion to the other side. 380(a)(4) apply to the award of expenses incurred as a result of making the motion. 26 (d) (1), “ [a] party may not seek discovery from any source before the parties have conferred as required by Rule 26 (f). Rule 3. (a) Separate statement required. 4003. Law, a legal research platform. The moving party asks the court to order the opposing party to produce documents or other information, often at their expense. Henson to produce I hereby certify that on July 08, 2020, I filed an electronic copy of the foregoing Respondent’s Motion to Compel Production of Documents Responsive to Respondent’s Second Set of Requests for Production, with: See appendix for sample of interrogatories and Request for Production designed to obtain the necessary information to establish that the documents are discoverable and will enable you to properly designate them in your motion to compel. Superior Court (1983) 147 Cal. 1 (b), served with a notice of deposition on oral examination or written questions. Discovery Motion Cut-Off--15 Days Before the Initial Trial Date Section 2025. Trachtman, Esq. Format of discovery motions. for Prod. 290(c) Delaying the filing of the motion waives a party's right to compel further responses. Apr 11, 2024 · Rule 4901-1-23 | Motions to compel discovery. Timing is critical and different for various types of discovery and depends on if a response is served. Jan 23, 2024 · A motion to compel is a request to the court to issue an order to compel the other party to answer a question or to produce a document or object. 310(b)(1). This Memorandum of Law (Motion to Compel Discovery) is a standard form attorneys can use to support a motion to compel discovery under New York Civil Practice Law and Rules (C. GREENE BROILLET & WHEELER, LLP (SPACE BELOW FOR FILING STAMP ONLY) LAWYERS 100 WILSHIRE BOULEVARD, SUITE 2100 P. Aug 14, 2015 · PLAINTIFFS' MOTION TO COMPEL PRODUCTION OF DOCUMENTS OR, IN. Any motion involving the content of a discovery request or the responses to such a request must be accompanied by a separate statement. v. Motion, Exhibit U, Resp. Mar 26, 2024 · The provisions of rule 1. FRCP 37 does not specify a time limit within which a motion to compel must be brought, but courts have required that a party seeking to compel discovery must do so in a timely Clerk Of Court C P, G S, And Family Court. See full list on legaldictionary. There are several requirements before someone can file a motion. (a) The party to whom the demand for inspection, copying, testing, or sampling is directed waives any objection to the demand, including one based on privilege or on the protection for work product under Chapter 4 (commencing with Section 2018. No. Lopez,Deputy Clerk 1 Marc A. 218. "Motion to Compel Plaintiffs to Produce Documents at Trial — Authentication": This specific motion aims to compel plaintiffs to produce documents that are relevant to the case but may question their authenticity or validity. which is relevant to the subject matter involved in the pending action. Rule 34 (a) of the Massachusetts Rules of Civil Procedure, 365 Mass. to Complaint Counsel at 7; Motion, Exhibit V, Resp. |. Any time you file a motion, you must give the other side notice. Keep the originals for your files. ) However, “litigants are not without protection against unnecessarily onerous application of the disclosure statutes. This guide contains forms and instructions for a Motion to Compel Discovery Responses, to be used if the other side in your California civil case completely fails to respond to your requests for production of documents, form interrogatories, or special interrogatories. Activision Sep 30, 2022 · Documents for Motion to Compel Production of Documents in Washington. When the Motion Can Be Made. Make sure you have a legal basis for filing a Motion to Compel. 06C-01-366JOH, at *5 (Del. Jan 21, 2015 · In this case, the defendants brought their motion under Rule 30. Jan 31, 2012 · In responding to Requests for Production of documents you have three response choices (1) agree to produce (C. In support of this Motion, Defendant relies upon and incorporates by reference the Aug 8, 2020 · The court summarized the problem inherent in a motion to compel production of documents that the responding party insists do not exist. 480(b) (amended eff 1/1/13) > > Read More. Miller, Jr. The answering or objecting party may file a response to the motion to compel. ACCORDINGLY, it is hereby ORDERED: Defendant’s Amended Motion to Compel First Request to Produce Documents Directed to Plaintiff (Doc. Carter, Executive Officer/Clerk of Court, by S. (1973) Rule 37 substantially follows Federal Rule 37. Aug 5, 2010 · Motions to compel further responses to interrogatories, requests for productions of documents and requests for admissions require that the motion be filed within 45 days. Writing a Compelling Motion to Compel. Too many defense lawyers think discovery is due after a motion compelling it gets granted. ’” (Pa. 06, which permits the court to make various orders, including an order to disclose or produce for inspection any non-privileged documents that were omitted from a party’s Affidavit of Documents, but which, based on evidence, is determined to be relevant to the litigation. R. jurisdiction’s statutes and rules governing production of documents from a nonparty. This motion is filed with the court. Pursuant to an Order issued on December 21, 2022 If the requesting party is not satisfied with the form stated by the responding party, or if the responding party has objected to the form specified by the requesting party, the parties must meet and confer under Rule 37(a)(2)(B) in an effort to resolve the matter before the requesting party can file a motion to compel. ; Arguments and Supporting Authorities why the court is authorized to compel discovery responses; Texas Rule of Civil Procedure 205. “A motion to compel production of documents is discretionary, and the party seeking production must affirmatively show that good cause exists for production. ” (Cunniffe, id. §2031. It is well settled that “on the motion of the party from whom discovery is sought, ORCP 36 C (1) permits the trial court to restrict or limit the terms and conditions of discovery, as justice requires [,] to protect a party or person from annoyance, embarrassment, oppression, or undue burden or expense. ) “Practice Book § 13-14 (a) provides in relevant part that a trial court ‘may, on motion [to compel production], make such order as the ends of justice The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; (2) To compel further responses to interrogatories; (3) To compel further responses to a demand for inspection of documents or tangible things; (4) To compel answers at a deposition; (5) To compel or to quash the production Jul 23, 2018 · Defendant Ruth Johnson (“Defendant”), by and through her attorneys, Dickinson Wright PLLC, moves this Court pursuant to FED. Production of documents are governed under subsections 1457-1459, and subsection 1474 of the Louisiana Code of Civil Procedure, Revised Statutes. App. 79(a), the Clerk is herby directed to incorporate the Order by. P. 24 A. (c) Unless notice of this motion is given within 45 days of the service of the verified response, or any supplemental verified response, or on or before any specific later date to which the demanding party and the responding party have agreed in writing, the demanding party waives any right to compel a further response to the demand. Defendants may raise concerns about the documents' source, integrity, or potential alterations, and request the November 13 and 14 emails between Marc Powers, Bob Johnson, and Neal Pratt. After each request and objection, the movant then includes a paragraph why Meet and Confer Requirement for a Motion to Compel Production of Documents. 425 and rule 1. Tex. You may need them for a motion to compel production later. Fed. FILED THE HONORABLE JOHN McHALE 1 2023 JUL 19 12:34 PM Department 43 2 Oct 27, 2021 · investigation-related documents that the plaintiffs maintain have been put at issue in this action. Any participant seeking discovery may file a motion to compel discovery, if: (1) A participant to whom a data request is made or upon whom an interrogatory is served under Rule 406 fails or refuses to make a full, complete, and accurate response; The Court is addressing the Motion to Compel Production of Documents by Debtors (the “Motion”), which the Official Committee of Unsecured Creditors (the “Committee”) filed to gain access to documents withheld on the basis of the attorney-client privilege and/or the attorney workproduct doctrine (the “Objections”). Whether ‘good cause’ exists should be determined by the facts and circumstances, on a case by case basis. The plaintiffs’ Motion to Compel Production of Allegedly Privileged Documents (the “Second Motion”), filed on September 30, 2021, seeks the production of all Journey and TransLoc privileged documents from the period Specifically, Complaint Counsel seeks to compel Respondent to produce documents in response to Complaint Counsel’s First Request for Production of Documents (“RFP”) number 22, described more fully below. This can include producing documents, answering interrogatories, or providing testimony. Suh, Civil Action No. (e) Administrative Law Judge Action on the Motion to Compel Jun 2, 2017 · Complaint Counsel recently requested that Impax agree to produce relevant documents at least. Discovery Motion Cut-Off--15 Days Before the Initial Trial Date 3 days ago · Civil Practice Law & Rules Section 3124. , physical evidence in the other party’s possession or control. The requirements for production of documents under OCGA § 9-11-34 apply to nonparties as well as parties to the litigation. If a deponent fails to answer questions or produce documents or other items, the deposing party may adjourn the deposition or complete the examination on other matters and bring a motion to compel at a later time. ’s First Set of Reqs. (2) To compel further responses to interrogatories; 12 13 (3) To compel further responses to a demand for inspection of documents or 14 tangible things; 15 16 (4) To compel answers at a deposition; 17 18 (5) To compel or to quash the production of documents or tangible things at a 19 deposition; 20 21 Ticketmaster's counsel said rather than propounding a new request, it would be making a motion to compel. The Defendant seeks an order from this Court that all documents listed on (j) The court shall impose a monetary sanction under Chapter 7 (commencing with Section 2023. 410, fails to appear for examination, or to proceed Furthermore, if a party seeks to compel a production but unduly delays seeking that relief, the court can treat the motion to compel as untimely. Below is a sample motion to compel discovery. [SBN 167820] Eric S. Mahoney, 126 A. Sanctions Imposed on Witness Who Deposition Subpoena for Production of Business Records (SUBP-010) (plus Attachment (MC-025)) Notice to Consumer or Employee and Objection (SUBP-025) (showing the signed proof of service on the back). Rule 4901-1-23. Jun 16, 2020 · Learn how to draft and respond to a motion to compel production of documents in California state superior court. Aug 23, 2021 · Motion to Compel Deposition - Motion to Compel, Filed. reference in the docket. Rule 45 had been amended in 2015 to allow a “documents only” subpoena against a nonparty . #137]. Jan 1, 2021 · Motion to Compel Deposition Testimony . Sanctions are awarded in the amount of $2,460 for this motion. This guide covers motions to compel interrogatories, document requests, and admissions. The procedures for a motion to compel vary from Sep 24, 2013 · Such an order may restrict access to the original document, or may allow access upon payment of costs associated with production of the original. The case of Vidal Sassoon, Inc. motion to compel Anna Anderson, Plaintiff, by and through her attorneys, Ronald V. Under Fed. 37 for full and complete responses to her First Set of Interrogatories and Document Requests to Plaintiffs. RULE 37. This template contains practical guidance, drafting notes, and alternate clauses. 450 - Motion to compel deponent testimony and production (a) If, after service of a deposition notice, a party to the action or an officer, director, managing agent, or employee of a party, or a person designated by an organization that is a party under Section 2025. ” (See Brady v. An application for an order to a party or to a deponent who Mar 25, 2004 · Rules of Civil Procedure, Special Counsel moves to compel the Honorable James E. that counsel has conferred with opposing counsel and has been unable to resolve the dispute, as provided for in Mar 8, 2023 · motion to compel further responses to a request for production of documents must “set forth specific facts showing ‘good cause’ justifying the discovery sought by the demand. Elements to keep in mind while filing the Motion to Compel is to mention the nature of the case, identify the question that needs to be answered or the object or document that is needed and explain how it relates to the case, attach the other party’s written refusal to make available the information or In addition, “[a] written notice and all moving papers supporting a motion to compel an answer to a deposition question or to compel production of a document or tangible thing from a nonparty deponent must be personally served on the nonparty deponent unless the nonparty deponent agrees to accept service by mail at an address specified on the The amendment makes the rule consistent with Fed. REQUEST FOR PRODUCTION OF DOCUMENTS NO. CIV. Conclusion WHEREFORE, PREMISES CONSIDERED, ERIC M. In issue in Defendant’s motion is a privilege log prepared by the Plaintiff. Super. #135] and plaintiffs‟ motion to compel 30(b)(6) testimony of KMM on additional topics and production of all documents related to the agreed and court-ordered deposition topics. Rule 37. a complete failure to respond to or object to discovery, and. Motion to Compel Compliance with Subpoena May 23, 2022. You cannot file a Motion to Apr 8, 2022 · A motion to compel might ask a court to order a party to respond to the following types of discovery requests: Production of Documents: A request for production of documents requires a party to produce documents that are relevant to the dispute at issue in the lawsuit. 1, 2024) you may ask each party What Is a Motion to Compel Production of Documents? Background “The Rules of Civil Procedure permit discovery of ‘any matter . 230, without having served a valid objection under Section 2025. ) A subpoena for personal or consumer records must be issued at least 20 days before the date of production. Sep 7, 2022 · General Information for Complaints and Motions. Motion to Compel Jan 19, 2023 · A motion to compel discovery is used to get the other side to answer any of the discovery types mentioned above when they have refused to do so. Nov 15, 2020 · motion to compel - motion to compel motion to compel further fr responses Preview Electronically FILED by Superior Court of California, County of Los Angeles on 05/11/2021 11:22 AM Sherri R. four business days in advance of future depositions and, if Impax fails to meet that timeline, consent to Complaint Counsel’s recalling relevant witnesses in Washington, D. When moving the court to compel a deposition under Tex. , to answer Interrogatories and Request for Production of Documents and to deem admitted Requests for Admission that were served The Court’s Decisions. Lawyer guide on motions to compel in Sacramento, California. ” (See OCGA § 9-11-34 (c); see also Sechler Code, 1560(b)(2) (requiring nonparty business to respond within 15 days of service). 270(c). Failure to disclose. law comprehensive legal database for any state court documents. The motions that require a separate statement include a motion: (1) To compel further responses to 3. 290 (requests for admission), allow a party to file a motion to compel further responses where the responses are evasive or incomplete, or if an objection is without merit or too general. (Fugazy v. 1 authorizes a party to compel discovery from a nonparty by serving a subpoena compelling a request for production of documents or tangible things, pursuant to Rule 199. 215. ) Absent a claim of privilege or attorney work product, the party who seeks to efforts on this motion overlapped with the meet and confer efforts on the companion motion to compel production of documents. (a) When an inspection, copying, testing, or sampling of documents, tangible things, places, or electronically stored information has been demanded, the party to whom the demand has been directed, and any other party or affected person, may promptly move for a protective order. 4 th 1476, 130 CR3d 751, 755–producing party ordered to pay more than $74,000 of costs incurred by opposing Cisco's continued use of discovery to harass Albritton must come to an end. 010 ). net Dec 12, 2020 · Motion to Compel Responses to Request for Production of Documents in California. 380(a)(2) is the most widely used vehicle for seeking sanctions as a result of discovery abuses. L. Although C. Summary. “That lead defense counsel has produced everything given to her, and that the material [sought] remains unaccounted for, can be true at the same time, and therein lies the difficulty. A motion to compel the production of documents, and more importantly an order to compel production of documents, may come only after a Civ. ” (CCP §2031. When the nonparty fails to cooperate with your subpoena, the Code provides that you may move for an order Nov 7, 2016 · The Bad: In this motion, the movant gives a background of the dispute and then lists the specific Document categories sought. at § 2025. MANDY GLENN- Plaintiff v STEVEN KENNEDY, et al. Time, Inc. Plaintiffs move for an order compelling defendant Microsoft to produce documents withheld on the grounds of privilege or in the alternative for an in camera inspection of particular documents. General Information for Complaints and Motions. Civ. This case is before the Court on PharMerica’s Motion To Compel Production Of Unprivileged Documents. to inspect and copy, any designated documents . “Any party may serve on any other party a request (1) to produce and permit the party making the request, or someone 2024 California Rules of Court. Motion/Compel. ” CCP §2031. Absent a claim of privilege or attorney work product, the party who seeks to Motions to compel disclosure are generally granted where a party has unreasonably refused to comply. If a person fails to respond to or comply with any request, notice, interrogatory, demand, question or order under this article, except a notice to admit under section 3123, the party seeking disclosure may move to compel compliance or a response. Civ. PLAINTIFF’S MOTION TO COMPEL DISCOVERY RESPONSES FROM DEFENDANT . What Is a Motion to Compel Responses to Request for Production of Documents? Code of Civil Procedure, § 2031. On motion to compel discovery or for a protective order, the party from whom discovery is sought shall show that the information is not reasonably accessible because of undue burden or cost. ) Moving to compel. 2 (b) (5) or Rule 200. 26 (f) requires the parties to meet and confer at least 21 days before a scheduling conference is held" to Requests for production can also be used to test, measure, photograph, etc. Jun 13, 2017 · In fact, sanctions may be assessed for production of documents that are in complete disorder if the court finds that the producing party is responsible for the disordered state! [Kayne v. Timing of Motion to Compel. Read court documents, court records online and search Trellis. 01: Motion for Order Compelling Discovery. 230) or (3) object (C. O. 2. 240(b) does specifically not state the May 3, 2023 · A motion to compel further responses to a request for production of documents must “set forth specific facts showing ‘good cause’ justifying the discovery sought by the demand. Zois, and Miller & Zois, LLC, requests that this Honorable Court compel Defendant, Louis Anthony Slavotinek, Jr. 1. ”. “Under OCGA § 9-11-37 (a) (2), a party may move to compel discovery responses to a document request under OCGA § 9-11-34. H Nov 3, 2023 · Procedural Steps Involved in Filing a Motion to Compel Production of Documents. ELECTRONICALLY FILED - 2023 Sep 21 8:28 AM - HAMPTON - COMMON PLEAS - CASE#2023CP2500020 STATE OF SOUTH CAROLINA IN THE COURT OF COMMON PLEAS COUNTY OF HAMPTON CIVIL ACTION NO: 2023-CP-25-00020 Elizabeth Brooks, Plaintiff, v. Document Request No. (Id. 380(a)(2) and the motion alleges. P. ) Code of Civil Procedure sections 2030. Pollard, Plaintiff Ace Jones moves this Honorable Court to enter an order compelling Defendant Michael Smith’s response to Plaintiff’s First Set of Interrogatories and Requests for Production of Documents. IN THE CIRCUIT COURT FOR BALTIMORE CITY, MARYLAND. The court will force the other side to do something they must do. There are a total of 24 document requests at issue. 1(a). 34 request. FILED THE HONORABLE JOHN McHALE 1 2023 JUL 21 02:42 PM Department 43 2 KING COUNTYNoted for Consideration: July 21, 2023 SUPERIOR COURT CLERK Without Oral Argument 3 E-FILED CASE #: 22-2-15880-8 SEA 4. 33, 34, and. Find sample documents, case law, and tips from Trellis. The movant dutifully lists each request and then quotes the objection made by the respondent. California law places strict limits on the number of discovery requests a party can make. 280(g) when they should be considered by the court in determining a matter pending before the court. uv em yj pf jj cv bz ke rn qn