Motion to compel drafting

• The exact requests and responses, including definitions, instructions and supplements.
• Service information and counsel’s confirmed motion deadline.
• Meet-and-confer correspondence, call notes and any agreements narrowing the dispute.
• The discovery plan, protective order, scheduling order and court-specific conference requirements.
• Requested relief by request number, proposed compliance terms and any expense request approved by counsel.

We place the request, response, asserted defect and requested order alongside one another. That comparison shows whether the dispute concerns an unanswered question, withheld documents, a search description, a privilege claim or an incomplete production. The brief can then focus on the remaining contested requests and acknowledge the issues already resolved through correspondence.

Federal Rule 37(a)(1) requires a certification of a good-faith conference or attempt to confer before seeking an order compelling discovery. The draft uses the actual record supplied by counsel; it does not invent a call or imply that a required conference occurred. Local procedures may require a joint submission, discovery conference or permission before a noticed motion.

The proposed relief identifies the requests at issue and the response, search or production counsel seeks. Rule 26(b)(1) informs relevance and proportionality in federal discovery. Requests for expenses, sanctions, a protective order or privilege relief receive separate treatment and are included only at counsel’s direction. State discovery motions are checked against their own statutes and rules.