Q: Motion to compel further, vs separate statements and proposed orders

A: Based on your question, it appears you're dealing with discovery motions in a California personal injury case. Let me break down the key points:

1. Motion to Compel Further Responses:

You're correct that you can generally consolidate motions to compel further responses for different discovery devices (like interrogatories and demands for production) into one motion. This is often more efficient and can save time and resources.

2. Separate Statements:

In California, separate statements are typically required for each discovery device. This means you would need to prepare:

- One separate statement for interrogatories

- Another separate statement for demands for production

3. Proposed Orders:

Similarly, proposed orders are usually prepared separately for each discovery device. You would likely need:

- One proposed order for interrogatories

- Another proposed order for demands for production

The reason for separate statements and proposed orders is to allow the court to review and rule on each discovery device independently, even if the motions are consolidated.

To confirm this understanding and get specific guidance for your case, I'd recommend:

1. Reviewing California Code of Civil Procedure Section 2016.040 and California Rules of Court, Rule 3.1345, which govern separate statements.

2. Checking your local court rules, as some courts may have specific requirements.

3. Consulting with a local attorney familiar with discovery practices in your specific court.