For motions to strike, motions to dismiss, and summary judgments (and responses to) almost all states' practice rules requires memorandum of law. Other motions & pleadings (compel, answer, special or affirmative defenses) do not require memos of law but you can include one if you wish.

You should answer the motion for default (is this due to a non-response to the complaint .... if so FILE a response (motion to revise, motion to strike, or answer [with affirmative defenses & counter claim]) to the complaint & an objection to the motion for default .... you don't want a default judgment & the hassle of opening up one...

Why a motion to compel?

What do you mean you do not know how to do a motion? Go to the courthouse & look at other case files for an idea .. its pretty easy to understand once you look at a few.

Quote Quoting Abby12
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Update;

At pretrial conference the judge allowed my request for production of docs which I send to plaintiff and also filed with the court to have it on record. Plaintiff had 30 days to reply yet absolutely no response.
Write the opposing consul a letter demanding that they provide you with the docs requested with 7 days or you shall file a motion to compel and request sanctions against them.