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MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT FOR ORDER COMPELLING RESPONSES TO REQUEST FOR PRODUCTION


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I am helping a friend with a case. The friend is the plaintiff. The other party was served, but when it came to serving a request for production of documents, and sending interrogatories they are refusing the mail.  So she wants to file a Motion to Compel. I am assuming in that we also need to file in the Motion, a declaration and also do we need a MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT FOR ORDER COMPELLING RESPONSES TO REQUEST FOR PRODUCTION within that motion and added to the tile of Motion of Motion to Compel etc, .

Do we also need to add this at the end - NOTICE OF TENTATIVE RULING SYSTEM . Is Sacremento, Ca the same as neighboring counties in that area of California. I called the court, they do not give advice but direct you to rules and I could not find the exact rule to use.  I her you have to send a meet and confer letter, but is that mute because they are not accepting the mail or service anymore- basically evading.

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