Q: Are all sub-components of Motion to Compel further discovery allowed to be compiled into one document?

A: In California, a Motion to Compel Further Discovery can typically include all the necessary sub-components in a single document. This is often referred to as a "Combined Motion." The California Rules of Court allow for this format to streamline the filing process.

A Combined Motion to Compel Further Discovery would usually include the following sections:

1. Notice of Motion and Motion: This section informs the opposing party of the date, time, and location of the hearing, as well as the basis for the motion.

2. Memorandum of Points and Authorities: This section presents the legal arguments and authorities supporting the motion.

3. Separate Statement: This is a detailed, itemized statement that identifies each discovery request at issue, the response given, and the reasons why further responses should be compelled.

4. Declaration: This is a sworn statement by the moving party or their attorney, setting forth the facts supporting the motion and demonstrating a good faith attempt to resolve the discovery dispute before filing the motion.

5. Proposed Order: This is a draft order for the court to sign, granting the relief requested in the motion.

These sections can be compiled into a single document, with a title such as "Notice of Motion and Motion to Compel Further Discovery Responses" and a footer on each page identifying it as a motion to compel further discovery.

However, it's always best to consult the local rules of the specific court where the motion will be filed, as some courts may have additional or varying requirements for the format and content of such motions.