A motion to compel asks the court to order a response to discovery that has been refused, evaded or answered incompletely. It is granted or denied largely on the quality of the record the movant has built.

Meet and confer is a real requirement. Nearly every court requires a good faith attempt to resolve the dispute first, with a certification describing it. A single email is rarely enough; a call or conference with a follow-up letter memorializing positions is the expected standard.

Build the record. The motion should attach the request, the response, the correspondence, and any narrowing offered. A movant who shows it offered to limit custodians, date ranges or search terms and was refused is in a far stronger position than one who demands everything.

Timing. Move promptly. A motion brought weeks after the discovery cutoff, on a dispute known for months, is often denied on delay alone regardless of merit.

Relief to request. Be specific about the order sought — which requests, what is to be produced, by when — and ask for a compliance deadline. A vague order is the seed of the next motion.

Fee shifting. Many rules require an award of expenses against the losing side unless the position was substantially justified. That cuts both ways, and it is a reason not to bring a marginal motion.