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Motion to Compel

Draft Motions to Compel in Minutes, Not Hours

12 minutes with CaseMark

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Motion to Compel

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Workflow

Motion to Compel

Overview

CaseMark's Motion to Compel skill drafts complete, filing-ready motion packages for discovery disputes in civil litigation. From boilerplate objection challenges to ESI format disputes, the AI generates deficiency matrices, memoranda of points and authorities, good-faith declarations, and proposed orders—all mapped to the correct federal or state procedural rules.

Drafting motions to compel is one of the most tedious tasks in civil litigation. Attorneys must manually cross-reference each discovery request against the opposing party's response, identify specific deficiencies, research applicable rules and local requirements, document the meet-and-confer record, and draft multiple interconnected documents—all under tight discovery deadlines.

CaseMark automates the entire motion-to-compel workflow. Upload your discovery requests, responses, and meet-and-confer correspondence, and the AI produces a complete motion package with a verbatim deficiency matrix, rule-mapped memorandum, conferral declaration, proposed order, and sanctions strategy—ready for attorney review and filing.

How it works

  1. 1. Upload your discovery requests, responses, objections, and meet-and-confer correspondence

  2. 2. AI maps each discovery item to applicable rules, identifies deficiencies, and builds a verbatim deficiency matrix

  3. 3. Review the complete motion package including memorandum, declaration, proposed order, and sanctions analysis

  4. 4. Export filing-ready documents in your preferred format (DOCX, PDF)

What you get

  • Rule Mapping & Deadline Analysis

  • Deficiency Matrix with Verbatim Quotes

  • Notice of Motion

  • Memorandum of Points and Authorities

  • Good-Faith Meet-and-Confer Declaration

  • Proposed Order

  • Sanctions Strategy & Fee Analysis

  • Filing-Readiness Checklist

What it handles

  • Deficiency matrix mapping each request to verbatim objections and deficiencies

  • Complete motion package with notice, memorandum, declaration, and proposed order

  • Rule 37(a)(5) sanctions strategy with fee calculations

  • Meet-and-confer certification with chronological conferral record

  • Federal FRCP and state analog support with local rule compliance checks

  • Proportionality and relevance analysis addressing boilerplate objections

Required documents

  • Discovery Requests Served

    The interrogatories, requests for production, requests for admission, or other discovery requests you served on the opposing party

    .pdf, .docx

  • Discovery Responses and Objections

    The opposing party's responses, objections, and any supplemental responses to your discovery requests

    .pdf, .docx

  • Meet-and-Confer Correspondence

    Letters, emails, and records of conferences documenting your good-faith efforts to resolve the discovery dispute

    .pdf, .docx, .eml, .msg

Supporting documents

  • Court Orders on Discovery

    Any existing court orders related to discovery schedules, deadlines, or prior discovery disputes

    .pdf, .docx

  • Local Rules or Standing Orders

    Applicable local rules or judge-specific standing orders governing discovery motions

    .pdf, .docx

  • Privilege Logs

    Any privilege logs produced by the opposing party that you contend are inadequate

    .pdf, .docx, .xlsx

Why teams use it

Reduce motion drafting time from hours to minutes with AI-generated deficiency matrices and memoranda

Ensure procedural compliance with automatic rule mapping for federal FRCP and state analogs including local rule requirements

Strengthen sanctions arguments with structured Rule 37(a)(5) analysis and fee documentation

Eliminate missed issues with systematic request-by-request deficiency analysis quoting verbatim objections

Questions

What types of discovery disputes does this handle?

CaseMark covers the full range of discovery disputes including interrogatories (Rule 33), requests for production (Rule 34), requests for admission (Rule 36), deposition disputes (Rules 30/31), subpoena compliance (Rule 45), and ESI format disputes. The AI maps each issue to the correct federal or state authority.

Does it work for state court motions or only federal?

CaseMark defaults to federal FRCP authority but automatically adapts to state court analogs when you specify a state jurisdiction. It also accounts for local rule requirements such as separate statements, page limits, pre-motion conferences, and joint discovery letters.

How does the deficiency matrix work?

The deficiency matrix quotes each discovery request and the opposing party's response verbatim, then identifies the specific deficiency—whether it's a boilerplate objection, incomplete answer, missing privilege log entry, or total non-response. This request-by-request analysis forms the backbone of your motion.

Does it include sanctions analysis under Rule 37?

Yes. CaseMark builds a Rule 37(a)(5) sanctions strategy including attorney fee calculations and the substantial justification framework. It identifies which sanctions arguments are strongest based on the opposing party's conduct and the meet-and-confer record.

Do I still need to verify meet-and-confer compliance?

CaseMark generates a meet-and-confer certification based on the correspondence and chronology you provide, but you should verify that all conferral efforts are accurately reflected. The AI flags potential gaps in your conferral record so you can address them before filing.

How filing-ready are the generated documents?

CaseMark produces a complete motion package—notice, memorandum, declaration, and proposed order—with proper legal citations and formatting. A built-in filing-readiness checklist flags issues like missing local rule requirements, but attorneys should always review and finalize before submission.

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