How do you write a motion to compel to answer interrogatories after 60 days have past?

I have sent interrogatories twice by certified by mail to the other party and I have received no response. The judge has told him that he is responsible / required to respond to my questions but he has failed to do so. Now I need to how to file a motion to compel. The trial is in 90 days.How do you write a motion to compel to answer interrogatories after 60 days have past?lawyer up before you blow the whole case