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Motion to Compel Discovery Responses

Obtaining an Order that the Opposing Side Respond to Discovery Requests

Sometimes, as you conduct discovery in your civil case, the opposing side fails to respond to your formal discovery requests. If the opposing side fails to respond to a Request for Admissions, your remedy is to ask the court for an order to have the facts you sought to have the other side admit deemed true. If the opposing side fails to respond to your Form or Special Interrogatories, or a Request for Production, you may file a motion seeking an order that the opposing party be compelled to respond. This guide provides step-by-step instructions for seeking such an order. This guide is for use when the opposing side fails to respond to interrogatories or a request for production of documents all together. If you are seeking further responses because the responses were served, but were incomplete or otherwise void (e.g., not verified), you would need to file a motion to compel further responses, which is not described in this guide.


There is no Judicial Council form for this procedure. Instead, the relevant document must be typed on 28-line pleading paper. Customizable templates may be downloaded from these links:

Click below to download this guide, with step-by-step instructions and sample forms:

 Motion to Compel Responses to Interrogatories Step by Step