A motion to compel asks the court to order the other side to respond to discovery they've refused, ignored, or answered incompletely. It's one of the most common motions in civil litigation — and one of the easiest to get wrong procedurally.
Meet and confer first — courts expect it
Most courts require a documented good-faith attempt to resolve the dispute directly with opposing counsel before a motion to compel will even be considered. Skipping this step is one of the most common reasons these motions get denied on procedural grounds.
Be specific about what's missing
A motion that vaguely complains about 'inadequate responses' is far weaker than one that walks through each disputed request, quotes the objection raised, and explains why it doesn't hold up.
Address objections on their own terms
Common objections — overbroad, unduly burdensome, privileged — each require a different rebuttal. A motion that responds generically to all of them misses the chance to dismantle the specific objection actually raised.
Ask for what you're actually entitled to
Beyond compelling a response, the motion can request sanctions or fee-shifting when the refusal was unjustified — worth including when the record supports it, since it changes the incentive for future discovery disputes.