Consumer Class Actions: 8.3 Compelling Discovery Responses
If the defendant objects to discovery or supplies insufficient, unresponsive, or equivocal responses, or no responses at all, the plaintiff should promptly file a motion to compel.267 Any motions to compel should be filed as soon as possible so that the defendant will perceive that the plaintiff is litigating the case aggressively and so that any delay of the litigation or of the class certification motion will be attributable entirely to the defendant.