![]() Do not forget to include a certification of good faith attempts to resolve the dispute.ģ. Once again, when filing the motion, state specifically the relief you are requesting and describe the steps that you have taken to attempt to resolve the discovery dispute on your own. If you feel that you are absolutely entitled to the information, inform your opposing party that you will file a motion to compel with the court. You will have to decide whether you believe the information is truly objectionable or necessary. Sometimes the opposing party may respond that they believe the information requested is objectionable or that they do not have the information. Give the party reasonable time to respond to your request. If you have a good faith basis for believing the response is insufficient, send a letter to the opposing party explaining why you believe the response was insufficient and what additional information you are requesting. What should I do if I feel my opposing party’s discovery responses are insufficient? You must include the date, time, and circumstances of each discussion or attempted discussion. The Maryland Rules require you to certify, at the end of your motion that, after taking steps to resolve the discovery dispute, you were unable to reach an agreement with opposing party. When filing a motion to compel, state specifically the relief you are requesting and describe the steps that you have taken to attempt to resolve the discovery dispute on your own. These motions are typically acts of last resort, which you should save for when your opponent fails to respond to any of your requests. A motion to compel asks the court to order the opposing party to respond to discovery by a certain date. If the opposing party still fails to respond within a reasonable time after your request, inform them that you will file a motion to compel with the court. Courts do not like to become involved in these disputes unless absolutely necessary. ![]() It is beneficial and expected by the Court that you participate in good faith discussions and grant an extension, if reasonable. ![]() Give your opposing party reasonable time to respond after your request in writing. If the opposing party has not responded to your requests, follow up in writing to see when they expect to have responses. What should I do if my opposing party is not responding to my discovery requests?
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