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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 transforms discovery dispute briefing from a tedious, multi-document drafting exercise into a streamlined AI-powered workflow. Upload your discovery requests, opposing responses, and meet-and-confer correspondence, and receive a complete filing-ready motion package—including a deficiency matrix, memorandum of points and authorities, good-faith declaration, and proposed order—in minutes instead of hours.

Drafting a motion to compel requires painstaking side-by-side comparison of discovery requests and responses, verbatim quoting of objections, rule-by-rule legal analysis, and assembly of multiple documents—notice, memorandum, declaration, and proposed order. Attorneys routinely spend 6-10 hours on a single motion, with the added risk of missing local rule requirements or failing to adequately document the meet-and-confer process.

CaseMark automates the entire motion-to-compel workflow. Its AI analyzes your discovery requests and responses, builds a comprehensive deficiency matrix with verbatim quotes, maps each issue to the correct procedural authority, and drafts a complete motion package with sanctions strategy—all while checking for local rule compliance and filing readiness.

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 draft motion package including memorandum, declaration, and proposed order

  4. 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 Meet-and-Confer Declaration

  • Proposed Order

  • Sanctions Strategy & Fee Analysis

  • Filing-Readiness Checklist

What it handles

  • Automated 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 and supporting authority

  • Meet-and-confer certification with chronological conferral narrative

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

  • Covers interrogatories, RFPs, RFAs, depositions, subpoenas, and ESI disputes

Required documents

  • Discovery Requests Served

    The interrogatories, requests for production, requests for admission, or deposition notices you served on the opposing party

    .pdf, .docx

  • Responses and Objections Received

    The opposing party's responses, objections, and any documents produced in response to your discovery requests

    .pdf, .docx

  • Meet-and-Confer Correspondence

    Letters, emails, and notes documenting your good-faith efforts to resolve the discovery dispute before filing

    .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 Log

    Any privilege log produced by the opposing party that you contend is deficient

    .pdf, .docx, .xlsx

Why teams use it

Eliminate hours of manual side-by-side comparison by auto-generating verbatim deficiency matrices

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) fee analysis and supporting authority

Produce consistent, professional motion packages that meet filing-readiness standards across jurisdictions

Questions

What types of discovery disputes does this handle?

CaseMark's Motion to Compel skill covers 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. It addresses boilerplate objections, incomplete responses, privilege log deficiencies, and total failures to respond.

Does it work for both federal and state courts?

Yes. CaseMark defaults to federal FRCP authority but automatically adapts to state procedural analogs when you specify a state court 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?

CaseMark 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 failure to respond. This matrix becomes the backbone of the memorandum and proposed order.

Does it include a sanctions analysis?

Yes. CaseMark builds a Rule 37(a)(5) sanctions strategy, including arguments for attorney's fees and costs. It identifies whether the substantially justified exception applies and drafts supporting authority for the fee award you're seeking.

How does CaseMark handle the meet-and-confer requirement?

CaseMark generates a detailed good-faith declaration from your conferral correspondence, organizing dates, methods, participants, concessions made, and remaining disputes into a chronological narrative that satisfies certification requirements under Rule 37(a)(1) and local rules.

Can I customize the relief requested?

Absolutely. CaseMark lets you specify the exact items to compel, response deadlines, ESI format requirements, privilege log demands, and the scope of sanctions sought. The proposed order is tailored to your requested relief.

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