Q: Motions to compel further discovery responses

A: Generally speaking, the best practice in California is indeed to file separate motions to compel further responses for different types of discovery devices (e.g., interrogatories and requests for production of documents). This is because each type of discovery is governed by different sections of the California Code of Civil Procedure and may have slightly different requirements.

However, your question touches on an interesting point about interconnected discovery requests. In some cases, it may be more efficient and logical to address related issues together. Here's a general approach that might be acceptable:

1. Consolidated motion and declaration: If the interrogatories and document production requests are closely related or interdependent, it could be reasonable to file a consolidated motion and supporting declaration. This would allow you to present a cohesive argument about why further responses are needed for both types of discovery.

2. Separate statements: Even with a consolidated motion, it's generally advisable to prepare separate statements for each type of discovery. This is because California Code of Civil Procedure § 2030.300 (for interrogatories) and § 2031.310 (for document requests) require specific information to be included in the separate statement for each type of discovery.

3. Separate proposed orders: It's typically best to prepare separate proposed orders for each type of discovery. This allows the court to rule on each set of discovery requests independently if necessary.

This approach could potentially balance the need for procedural correctness with the practical reality of interconnected discovery requests. However, it's important to note that the acceptability of this approach may vary depending on the specific court, judge, and circumstances of your case.

Before proceeding, I would recommend:

1. Reviewing local court rules and any standing orders from the judge assigned to your case, as they may provide specific guidance on how to handle such situations.

2. Considering reaching out to the court clerk or reviewing past rulings by the judge to see if there's any precedent for handling interconnected discovery motions in this way.

3. Consulting with an experienced local attorney who regularly practices in the court where your case is pending. They may have insights into the preferences of specific judges or unwritten local practices.

Remember, while efficiency is important, it's crucial not to sacrifice procedural correctness. If in doubt, filing separate motions for each type of discovery is the safest approach to ensure compliance with California civil procedure rules.