Q: Compelling further responses to demands for production of esi
Can further responses to demands for esi be included in motion to compel further responses to demands for production?
A:
Yes, you can include further responses to demands for electronically stored information (ESI) in a motion to compel further responses to demands for production. Under California law, if you believe the responses to your demands for ESI are inadequate or incomplete, you have the right to file a motion to compel further responses.
To do this, you need to demonstrate that the responses provided were insufficient or that the other party has failed to comply with the discovery requests. The motion should detail the specific deficiencies in the responses and explain why further information or documents are necessary for your case.
When filing the motion, ensure you follow the proper procedural requirements, such as meeting and conferring with the opposing party before filing. This step is essential to show the court that you attempted to resolve the issue without judicial intervention.
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