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The first 10 requests for production of documents were for emails of 10 individuals which defendant refused to produce. In

San Jose, CA |

filing for motion to compel further responses, can I provide only one argument of compelling further response to all the 10 requests for production instead of 10 identical arguments? If yes, how is it done so as not to confuse the judge?

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Attorney answers 3


Yes. If you are specifically referring to the Separate Statement that is required in connection with a Motion to Compel Further Responses, your "argument" section can simply state "Please refer to discussion under Request for Production No. 1, which is incorporated herein by reference."

Frank W. Chen has been licensed to practice law in California since 1988. The information presented here is general in nature and is not intended, nor should be construed, as legal advice for a particular case. This posting does not create any attorney-client relationship with the author. For specific advice about your particular situation, please consult with your own attorney.


I agree with Mr. Chen. However, in the event you require the e-mails of these 10 individuals for varying reasons, the only thing I'd add is that you may want to include specific information in each separate statement as to why the production of each individual's emails is relevant and necessary. Best of luck.

Please be advised that this answer is for general informational purposes only. This answer does not constitute legal advice, and does not create an attorney-client relationship.


it depends on how you are drafting your motion. The separate statement is reqd to set forth the verbatim discovery requests, and the other party's verbatim responses/objections. Then below each one at issue in the motion, you want to set out the reasons further answers/production should be ordered. You should do that for each of these. and then maybe when you get to the reasons, spell it all out in the first one, and then for any others where the exact same reasons are asserted by you, just put something like : " pltf refers to his reasons for compelling production as set forth regarding Request For Production number __ above, and incorporates those same reasons as though set forth herein.."

You may also want to discuss in your points and authorities, the legal basis for your obtaining the emails at issue.