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Motion to Compel or Limine **Help Please See CA Reponse**

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I serve discovery April 1, 2012, they responded May 1, 2012 with proof of service. The first letter sent out May 7, 2012 and they responded to first letter May 17, 2012. So I think there still time left, but the question is:

A) Should I Motion to Compel Now or

B) Sent another letter detail my request with 7 days deadline, then Motion to Compel or

C) Just wait until 30 prior to trial then Motion to Preclude all the questions and items requested with no responses or insufficient responses or

D) Do nothing and prepare for MSJ and trial which is July 30, 2012.

Unless plaintiff has already filed the motion, it does not have sufficient time to file and serve a MSJ motion. A party must give 75 days' notice (plus 5 if served by mail) and the hearing must be held at least 30 days before trial.

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*** What is the right timing to file a motion in limine?? Does it have to be after all discovery is done but 30 days prior to trial? So far I requested credit application with defendant signature and payments documents with plaintiff objections using regulation Z two years compliance. Is that enough to motion for limine or should I wait for more discovery objections and denials. My trial date is July 30, 2012, I heard it too late for them to file MSJ. So I think they will hit me with CCP98 next. All my discovery requested will be due June 24, 2012.

*** Does anyone here know of a good sample or sticky for California superior court civil case in the forum?

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