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  1. Hi- These forums have been extremely helpful as we've prepared defense paperwork on what appears to be junk debt buying by LVNV Funding represented by Nelson Kennard in Sacramento, CA. We responded to their discovery req. for Adm, Prod of Docs and Form Interrog. with help from many on this forum. We've met for CM and Settlement Conf. and trial date is set for 6/6/14. (At the CM and Settlement Conf., Nelson& Kennard sent a local atty who was not familiar with the case and appeared confused. He did agree to the trial date) We sent our own Discovery request on 12/31/13 and Plaintiff has not responded at all. We have read a lot of conflicting information on Motion to Compel - should it be sent? We've read on the forum that it forces the Plaintiff to do their homework, and it may be better to sit back and respond to any of their filings. We want to make sure we follow through with best practice for a most positive outcome. What is the next best step for us? More importantly, how do we correctly create and file a Motion to Compel Discovery and how do we create and file a "Motion to Deem admitted" our Req. for Admissions? We've researched and can't seem to find a "template" to follow for these 2 items. We would appreciate any guidance. On the forums, we've read that the date for the 45 day time period clock for filing a Motion to Compel starts with the date that the Responding party actually responds. We have not received any response, so are wondering if there is any due date for this since the time clock has not appeared to start. Lastly, can we request sanctions? How much is reasonable and is this a separate motion as well? Thanks!