Q: motions to compel further responses to interrogatories & motion to compel further responses to production demands into 1

A: While it's generally preferable to file separate motions for different discovery issues, in some cases it may be possible to consolidate related motions to compel. Here's a breakdown of the key considerations:

1. Court discretion: Ultimately, whether this is allowed may depend on the specific court and judge. Some courts might permit a consolidated motion, while others may prefer separate filings.

2. Related issues: If the interrogatories and production demands are closely intertwined and deal with similar subject matter, there may be a stronger argument for consolidation.

3. Efficiency: Consolidating the motions could potentially save time and resources for both the court and the parties involved.

4. Clarity: Ensure that combining the motions doesn't sacrifice clarity. The court must be able to easily distinguish between the two types of discovery requests and their respective issues.

5. Separate statements: As you mentioned, you would still need to provide separate statements for each type of discovery request, as required by California court rules.

6. Different legal standards: While the memorandum of points and authorities may be similar, be sure to address the specific legal standards and code sections applicable to each type of discovery request.

7. Court rules: Check your local court rules and the California Rules of Court for any specific guidance on consolidating discovery motions.

8. Labeling: If you do combine the motions, clearly label it as a consolidated motion addressing both interrogatories and production demands.

9. Meet and confer: Ensure you've thoroughly met and conferred on both types of discovery issues before filing the motion(s).

10. Consider asking opposing counsel: You might want to confer with opposing counsel about your intention to file a consolidated motion. They may agree or object, which could inform your decision.

Given the potential complexities, it may be advisable to:

1. File separate motions to ensure full compliance with procedural requirements.

2. If you decide to consolidate, consider filing a notice of motion explaining your reasoning for the consolidated filing and requesting the court's permission to proceed in this manner.

3. Consult with a local attorney familiar with the practices of your specific court for the most accurate guidance.

Remember, while consolidating motions might seem efficient, it's crucial to ensure that it doesn't compromise the clarity of your arguments or your ability to fully address each discovery issue.