Is only a notice of motion required to initiate a motion to compel further responses?
2 attorney answers
There are several necessary parts to a motion. First you need notice, and second you need the motion. This is usually combined in one document, (e.g. Plaintiff John Doe gives notice to Defendant Jane Roe that on March 1, 2022, in Department 99 of the Kangaroo Court, Plaintiff moves for Jaberwocky under CCP 8898.87, followed by whatever tentative ruling language is required by local rules). Along with the Notice, the motion needs to be supported by a Memorandum (of Points and Authorities) that explains the legal argument supporting your motion. Any factual support must be brought in through admissible evidence, usually a supporting declaration or a request for judicial notice. Many times a [Proposed] Order is included for the Judge to sign if she agrees with your motion. This has not been required for most motions since 2007, but it is a common practice. You may be required to include one on certain motions, say an ex parte application. You will have to check the statutes, the California Rules of Court (start around 3.1110), and any Local Rules of Court.
Finally, you may need to reserve a hearing date for your motion with the Court. If so, that reservation number is going to need to be in your caption. There is often a significant delay in scheduling certain types of motions in the County you are located, so plan ahead.
All of this sounds complicated. It is. If you can get some legal help here, it would be worth your while, even if you are just asking a local lawyer to review the format of your papers before filing.
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