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Separate Statement in Support of Motion to Compel Further Responses Website - Blog - Twitter Posted by Robin Mashal on 01.21.10 in Litigation-Law & Motion
http://www.courts.ca.gov/cms/rules/index.cfm?title=three&linkid=rule3_1345
(a) Separate statement required Any motion involving the content of a discovery request or the responses to such a request must be accompanied by a separate statement. The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; (2) To compel further responses to interrogatories;
https://www.avvo.com/legal-answers/response-to-a-separate-statement-in-support-of-a-m-3983142.html
The moving party's separate statement ("SS") in support of motion to compel further responses to form interrogatories 17.1 does not provide any argument or facts to support compelling a response under each request for admission that is not an unqualified admission.
https://www.resolvingdiscoverydisputes.com/abuse/game-on-the-opposition/
Sep 09, 2010 · You have been served with the Motion to Compel Further Responses with a Separate Statement of Items in Dispute the size of your fist and your response is due in two weeks. Now what do you do? First, take a deep breath. This is the time you decide when to "hold them and when to fold them" because how you respond may end up setting the tone between you and opposing counsel for the …
https://www.resolvingdiscoverydisputes.com/motions/what-should-your-discovery-motions-look-like/
Aug 27, 2010 · Separate Statement of Items in Dispute. This is the most important document of your motion and the first document that a court will rely on. Do your real argument here. Be detailed in the law as to why the objections are garbage. Apply the facts of your case to show why the information you are seeking is discoverable.
https://www.litigationbythenumbers.com/motion-to-compel.html
Jul 09, 2019 · Separate statement: All motions to compel further responses in California state court must include a separate statement in accordance with C.R.C., Rule 3.1345, stating the specific discovery request, the response given, the factual and legal reasons for compelling further responses, etc.
https://californialawblog.wordpress.com/2012/07/20/reply-separate-statements-are-improper-in-a-motion-for-summary-judgment/
Jul 20, 2012 · As part of the Motion for Summary Judgment and/or Motion for Summary Adjudication filing, attorneys sometimes submit a document titled “Reply Separate Statement.” In the Reply Separate Statement, the moving attorneys will raise objections to the evidence cited in the opposing party's Separate Statement and also cite to additional evidence to refute the opposing party's’s…
http://www.courts.ca.gov/cms/rules/index.cfm?title=three&linkid=rule3_1350
(d) Separate statement in support of motion (1) The Separate Statement of Undisputed Material Facts in support of a motion must separately identify: (A) Each cause of action, claim for damages, issue of duty, or affirmative defense that is the subject of the motion; and
https://saclaw.org/wp-content/uploads/sbs-motion-to-compel-discovery-responses.pdf
• Declaration of [Name] in Support of the Motion. At the end of this Guide is a sample motion with declaration and points and authorities for compelling responses to both interrogatories and requests for production. Customizable templates may be downloaded from the links below: • Notice of Motion and Motion to Compel Responses to
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