Having reviewed thousands of Motions to Compel Further Responses over the years, I rely heavily on the separate statement filed with these motions.  Unfortunately, I find that many of the separate statements are deficient and not in compliance with Rule 3.1345 of the California Rules of Court.  This inevitably hurts the moving party as I search for the information that should have been in the Separate Statement. However, beware, Courts routinely deny these motions when the separate statement fails to be in compliance with CRC, Rule 3.1345.Continue Reading Does Your Separate Statement Contain All the Required Information for a Motion to Compel Further Responses?