Q: Motion to Compel further responses to interrogatories and to production demands

A: Yes, a Motion to Compel further responses can include both compelling responses to special interrogatories and production demands in California.

Key points:

1. Combined motion: In California civil procedure, it's common and often efficient to combine motions to compel further responses for different types of discovery in a single motion.

2. Legal basis: This is typically done under California Code of Civil Procedure (CCP) sections 2030.300 (for interrogatories) and 2031.310 (for document production).

3. Meet and confer requirement: Before filing the motion, the moving party must make a good faith attempt to meet and confer with the opposing party to resolve the discovery disputes without court intervention.

4. Time limits: Generally, a motion to compel further responses must be filed within 45 days after service of the verified response, or on or before any specific later date to which the parties have agreed in writing.

5. Scope: The motion should clearly specify which interrogatories and production demands require further responses, and why the initial responses were inadequate.

6. Supporting documentation: The motion should be accompanied by a separate statement for each type of discovery, detailing the specific items in dispute and the reasons for compelling further responses.

7. Potential sanctions: The court may impose monetary sanctions against the losing party in a motion to compel.