Motion To Compel - Under California State Court Rules

Under California State Court Rules

Pursuant to California Rule of Court 3-1345:

(c) Contents of separate statement

A separate statement is a separate document filed and served with the discovery motion that provides all the information necessary to understand each discovery request and all the responses to it that are at issue. The separate statement must be full and complete so that no person is required to review any other document in order to determine the full request and the full response. Material must not be incorporated into the separate statement by reference. The separate statement must include-for each discovery request (e.g., each interrogatory, request for admission, deposition question, or inspection demand) to which a further response, answer, or production is requested-the following:

(1)The text of the request, interrogatory, question, or inspection demand;

(2)The text of each response, answer, or objection, and any further responses or answers;

(3)A statement of the factual and legal reasons for compelling further responses, answers, or production as to each matter in dispute;

(4)If necessary, the text of all definitions, instructions, and other matters required to understand each discovery request and the responses to it;

(5)If the response to a particular discovery request is dependent on the response given to another discovery request, or if the reasons a further response to a particular discovery request is deemed necessary are based on the response to some other discovery request, the other request and the response to it must be set forth; and

(6)If the pleadings, other documents in the file, or other items of discovery are relevant to the motion, the party relying on them must summarize each relevant document.