Motions to Compel

declaration of counsel submitted in connection with reply brief on motion to compel to counter assertions made in opposition

Opening brief in support of motion to compel further responses to interrogatories and request for production of documents

supporting declaration submitted to provide evidence in support of motion to compel and showing met and conferred prior to filing motion

another example of motion to compel responses to discovery, related to arbitration issues

form of notice of motion that describes nature of relief being requested and hearing date

reply memorandum in support of motion to compel, this one related to injunction and class certification related discovery

reply memorandum in support of motion to compel, related to arbitration discovery

form of separate statement need to submit as part of motion to compel. This statement references special interrogatories

separate statement format for request for production of documents related to arbitration issues

format of separate statement for interrogatories related to requests for arbitration type discovery