[COURT NAME]
[COUNTY], [STATE]

[PLAINTIFF NAME], )
Plaintiff, ) Case No. [CASE NUMBER]
v. )
[DEFENDANT NAME], )
Defendant. )

MOTION TO COMPEL DISCOVERY AND REQUEST FOR EXPENSES

NOTICE OF MOTION AND MOTION

PLEASE TAKE NOTICE that on [HEARING DATE] at [TIME], or as soon thereafter as counsel may be heard, [MOVING PARTY] will and hereby does move the Court for an order compelling [OPPOSING PARTY] to provide full and complete responses to [INTERROGATORIES/REQUESTS FOR PRODUCTION/REQUESTS FOR ADMISSION] served on [DATE]. [MOVING PARTY] also requests an award of reasonable expenses, including attorney fees, as permitted by law.

MEMORANDUM OF POINTS AND AUTHORITIES

I. Introduction

This motion is necessary because [OPPOSING PARTY] has refused to provide meaningful discovery responses despite good-faith efforts to resolve the dispute without court intervention.

II. Background and Discovery at Issue

• Discovery served on: [DATE]
• Responses due on: [DATE]
• Deficiencies: [IDENTIFY REQUESTS AND OBJECTIONS]

III. Meet and Confer Efforts

[DESCRIBE MEET-AND-CONFER EFFORTS, DATES, AND OUTCOME.]

IV. Legal Standard

Parties may obtain discovery regarding nonprivileged matter relevant to any claim or defense and proportional to the needs of the case. A party must provide complete, non-evasive responses. Courts may compel discovery and award expenses when a party fails to respond or provides improper objections.

V. Argument

A. The requested discovery is relevant and proportional.
[Explain relevance to claims or defenses and proportionality factors.]

B. The responses are incomplete, evasive, or unsupported.
[Identify improper objections, boilerplate responses, or failures to produce.]

C. Any privilege claims must be supported by a proper log.
If privilege is asserted, [OPPOSING PARTY] must provide a privilege log describing the withheld materials.

VI. Requested Relief

[MOVING PARTY] respectfully requests an order that:
1. Compels complete responses to [LIST REQUESTS] by [DATE].
2. Requires production of responsive documents by [DATE].
3. Deems objections waived to the extent not specifically sustained by the Court.
4. Awards reasonable expenses, including attorney fees, as permitted by law.
5. Grants any other relief the Court deems just.

CONCLUSION

For the foregoing reasons, the Court should grant the motion to compel.

Respectfully submitted,

text
Dated: [DATE]

______________________________
[ATTORNEY NAME]
[LAW FIRM]
[ADDRESS]
[PHONE]
[EMAIL]
Attorney for [MOVING PARTY]

CERTIFICATE OF SERVICE

I certify that on [DATE], I served the foregoing Motion to Compel Discovery on all counsel of record via [METHOD OF SERVICE].

text
______________________________
[ATTORNEY NAME]

[PROPOSED] ORDER

The Court, having considered [MOVING PARTY]'s Motion to Compel Discovery, ORDERS as follows:
1. [OPPOSING PARTY] shall serve complete responses to [LIST REQUESTS] by [DATE].
2. [OPPOSING PARTY] shall produce responsive documents by [DATE].
3. [MOVING PARTY]'s request for expenses is [GRANTED/DENIED].

IT IS SO ORDERED.

Dated: [DATE]

__________________________________
[JUDGE NAME]
[STATE] Judge