Phone company records are difficult to obtain.  I say difficult, not impossible.  Even with a validly issued civil subpoena, the phone company will not comply without a notarized written consent from the consumer who “owns” the phone number.  You need a signed and notarized form such as this: Sprint Consent to Release Information

Pub. Util.

The Courts may exclude  evidence as a sanction as part of its  inherent power to exclude evidence to cure violation of invasion of privacy and harassment (see Continental Ins. Co. v. Superior Court (1995) 32 Cal.App.4th 94, 107-108)  This is based upon the concept that litigation abuse shall not be tolerated.  This case was about unethical ex parte communications with a current employee of a represented party (Rule 2-100).
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discoveryCCP §1170.8 states that motions to compel may be filed with only 5 day (plus service) notice.  Also oppositions and replies may be made verbally at the time of the hearing.

Rule 3.1347. Discovery motions in summary proceeding involving possession of real property

  • (a) Notice  In an unlawful detainer action or other action brought under

Do-Something-Save-Paper-logoUsually discovery is served in groups, e.g. Form interrogatories, Request for Admissions, Request for Documents.  If no response is provided I file a combined motion to compel these initial discovery responses.  I did this after several judges told me why not combine them and save filing fees and paper.  Once a judge told me not to do a combined motion only as a warning, not a denial of the motion.  Nothing in the Rules of Court that I found say you cannot combine discovery motions.  Here is my statutory analysis of this issue:
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