The motion to compel is used to ask the court to order the non-complying party to produce the documentation or information requested, and/or to sanction the non-complying party for their failure to comply with the discovery requests.
Thereafter, if the questions have not been adequately responded to, then the moving party may ask the court for a motion to compel.
California requires that the moving party provides a statement in support of the motion to compel.
Failure to Participate in Framing a Discovery Plan: If a party or its attorney fails to participate in good faith in developing and submitting a proposed discovery plan as required by Rule 26(f), the court may, after giving an opportunity to be heard, require that party or attorney to pay to any other party the reasonable expenses, including attorney's fees, caused by the failure.
However, if the responses are merely insufficient, the propounding party has a 45-day limit in which to submit the motion to compel.