Q: Meet and confer prior to motion to compel, generally not mandatory

A: Where a party responds to discovery, the meet and confer requirements are applicable.

A: Hi - Joel is correct. Meet and Confer requirements apply.

A: In California, yes - you must meet and confer before filing a motion to compel discovery responses, even when facing consistent objections. This requirement stems from California Code of Civil Procedure § 2016.040, which makes it mandatory to make a reasonable and good faith attempt to resolve discovery disputes informally before seeking court intervention.

The purpose behind this rule is to promote efficiency and reduce court congestion by having parties attempt to resolve their discovery disagreements without judicial involvement. Even if you believe the opposing party's objections are baseless or made in bad faith, you still need to document your attempts to meet and confer. Courts take this requirement seriously and may deny your motion to compel if you cannot demonstrate compliance.

The meet and confer process should include a meaningful attempt to discuss the specific discovery requests and objections at issue. This typically involves written correspondence and at least one verbal discussion, where possible. Be sure to keep detailed records of all meet and confer attempts, including dates, methods of communication, and summaries of the discussions, as you'll need to include this information in your motion to compel declaration.