In the U.S. District Court for the Middle District of Florida, Local Rule 3.04(a) governs motions to compel discovery. Before filing a motion to compel in a civil case, counsel are required to confer in good faith concerning the requested relief and must include a certificate of conference in the motion. If counsel are unable to work out the discovery dispute, then a motion to compel discovery must take the following format:

The motion must quote in full each interrogatory, question on deposition, request for admission, or request for production to which the motion is addressed;
Each discovery request at issue must then be followed immediately by quotation in full of the objection and grounds therefor as stated by the opposing party, or the answer or response which is asserted to be insufficient; and
Each response to the discovery request at issue must then be immediately followed by a statement of the reasons why the motion to compel should be granted as to the discovery request at issue.

The opposing party has a deadline of 14 days after service of a motion to compel to file a response of not more than 20 pages that includes a memorandum of legal authority in opposition to the motion.

Joel Ewusiak frequently represents parties in lawsuits pending in the U.S. District Court for the Middle District of Florida. Please contact Joel for legal assistance with your specific matter.