Motion to Compel

Draft Filing-Ready Motions to Compel in Minutes

12 minutes with CaseMark

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Upload your documents and get a finished work product in minutes. New accounts get $5 free to run their first skill.

12 minutes with CaseMark

What you'll need

Discovery Requests Served
Discovery Responses and Objections
Meet-and-Confer Correspondence

SOC 2 Type II · HIPAA compliant · $5 free credit

Workflow

Overview

CaseMark's Motion to Compel skill transforms discovery dispute briefing from a multi-hour drafting exercise into a streamlined, AI-assisted workflow. Upload your discovery requests, responses, and meet-and-confer correspondence, and receive a complete filing-ready motion package—including a verbatim deficiency matrix, memorandum of points and authorities, good-faith declaration, and proposed order. The skill handles federal FRCP and state court analogs across all major discovery types.

Drafting a motion to compel requires painstaking comparison of each discovery request against the opposing party's response, mapping objections to the correct rule authority, documenting meet-and-confer efforts, and assembling multiple documents into a cohesive filing. This process routinely consumes 4-8 hours of attorney time per motion, and errors in citation or incomplete deficiency analysis can undermine the motion's effectiveness.

CaseMark automates the entire motion-to-compel workflow by analyzing your discovery requests and responses, building a verbatim deficiency matrix, mapping each dispute to the applicable rule authority, and generating a complete motion package with memorandum, declaration, and proposed order. The result is a filing-ready motion produced in minutes that meets federal and state court requirements, freeing attorneys to focus on strategy rather than document assembly.

How it works

1. Upload your discovery requests, responses, objections, and meet-and-confer correspondence
2. AI maps each dispute to the applicable rule authority and builds a verbatim deficiency matrix
3. Review the complete motion package including memorandum, declaration, and proposed order
4. Export filing-ready documents in your preferred format (DOCX, PDF)

What you get

Rule Mapping & Deadline Analysis
Deficiency Matrix
Notice of Motion
Memorandum of Points and Authorities
Good-Faith Declaration with Meet-and-Confer Certification
Proposed Order
Sanctions Strategy Under Rule 37(a)(5)
Filing-Readiness Checklist

What it handles

Deficiency matrix with verbatim request-response mapping
Rule-mapped memorandum of points and authorities
Good-faith meet-and-confer declaration
Rule 37(a)(5) sanctions strategy and fee calculation
Proposed order with specific compliance deadlines
Filing-readiness checks for federal and state court requirements

Required documents

Discovery Requests Served
The interrogatories, requests for production, requests for admission, or deposition notices you served on the opposing party
.pdf, .docx
Discovery Responses and Objections
The opposing party's responses, objections, and any supplemental responses received
.pdf, .docx
Meet-and-Confer Correspondence
Letters, emails, and notes documenting your good-faith efforts to resolve the discovery dispute informally
.pdf, .docx, .eml, .msg

Supporting documents

Court Orders on Discovery
Any existing court orders related to discovery schedules, protective orders, or prior discovery disputes
.pdf, .docx
Local Court Rules
Applicable local rules governing discovery motions, including separate statement requirements and page limits
.pdf, .docx
Privilege Logs
Any privilege logs produced by the opposing party that you contend are deficient
.pdf, .docx, .xlsx

Why teams use it

Eliminate hours of manual request-by-request comparison with automated verbatim deficiency matrices

Ensure correct rule mapping and authority citations for every discovery type and jurisdiction

Produce court-ready motion packages that include all required components from notice to proposed order

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

Questions

What types of discovery disputes does this handle?

CaseMark's Motion to Compel skill covers interrogatories, requests for production, requests for admission, depositions, subpoena disputes, and ESI format issues. It maps each dispute to the correct federal rule or state analog and addresses common boilerplate objections.

Does it work for both federal and state courts?

Yes. CaseMark defaults to federal FRCP authority but adapts to state court analogs when you specify the 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, or missing privilege log entry. This format is what courts expect and makes your motion immediately persuasive.

Does it include a sanctions analysis?

Yes. CaseMark automatically includes a Rule 37(a)(5) sanctions strategy, analyzing whether the opposing party's position was substantially justified and calculating reasonable attorney fees and costs to include in your request for relief.

Can I customize the proposed order?

Absolutely. CaseMark generates a proposed order with specific compliance deadlines and relief terms that you can review and modify before filing. You can adjust response timelines, privilege log requirements, and sanctions amounts to match your case needs.

How does it handle meet-and-confer certification?

CaseMark drafts a good-faith declaration documenting your meet-and-confer efforts, including dates, methods, participants, concessions made, and remaining disputes. This satisfies Rule 37(a)(1) certification requirements and demonstrates the court that informal resolution was attempted.