A Checklist addressing motions to compel discovery in actions pending in the New Jersey Superior Court, Law Division, Civil Part or in non-foreclosure actions in the Chancery Division, General Equity Part. It sets out counsel's first steps before moving to compel discovery and explains how to draft, file, and serve the motion papers. It also addresses cross-motions for a protective order and post-motion procedure, including what to do if the deficient party fails to comply with an order compelling discovery.