This guide contains generic forms and instructions for filing a typical motion, opposition, or reply in California state court. You may file a motion seeking an order compelling the opposing party to respond.This Guide provides step-by-step instructions for seeking such an order. Attorneys will, for example, assert unnecessary objections to Judicial Council Form Interrogatories, or withhold information based on privilege. Yes, a failure to timely respond to discovery requests normally results in a waiver of legal objections. Just filing a notice of appearance leaves both the pro se and the new attorney as attorneys.