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DISTRICT COURT OF - Case No.: 123456-123

The defendant filed a motion to compel the plaintiff to respond to discovery requests. The discovery requests were served on November 15, 2009 and the plaintiff's responses were due by December 15, 2009. As of the date of the motion, December 20, 2009, the plaintiff had not provided any responses or indicated that they would provide the requested information. The defendant made a good faith effort to obtain the responses by contacting the plaintiff's counsel in writing on December 8, 2009 and by phone on December 12, 2009, but received no response. The motion asks the court to compel the plaintiff to respond to the outstanding discovery requests.

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191 views2 pages

DISTRICT COURT OF - Case No.: 123456-123

The defendant filed a motion to compel the plaintiff to respond to discovery requests. The discovery requests were served on November 15, 2009 and the plaintiff's responses were due by December 15, 2009. As of the date of the motion, December 20, 2009, the plaintiff had not provided any responses or indicated that they would provide the requested information. The defendant made a good faith effort to obtain the responses by contacting the plaintiff's counsel in writing on December 8, 2009 and by phone on December 12, 2009, but received no response. The motion asks the court to compel the plaintiff to respond to the outstanding discovery requests.

Uploaded by

John Goodwin
Copyright
© Attribution Non-Commercial (BY-NC)
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOC, PDF, TXT or read online on Scribd
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Attorney 123 Main Street Anytown, US 12345

DISTRICT COURT OF ___________________


) ) ) ) ) ) ) ) ) )

Joe Smith, Plaintiff, vs. ABC Plumbing, Inc, Defendant

Case No.: 123456-123

MOTION TO COMPEL

This motion can be filed by either Plaintiff or Defendant for failure to answer Discovery. Pursuant to local rules, Defendant hereby moves the Court be compelled to respond to Discovery based on the following facts: 1. 2. Discovery was filed on November 15, 2009. The Plaintiffs Responses to Discovery were due no later than December

15, 2009. To date, no Response has been received. 3. A good faith effort has been made to recover the Plaintiffs Responses.

On December 8, 2009, counsel for the Defendant requested in writing to Plaintiffs counsel for a response, noting that if responses were not received by December 15, 30 days after service of Discovery, a Motion to Compel would be filed. On December 12, 2009, a phone message was left with Defendants counsel asking for Responses. No return call was received. 4. The Plaintiff has refused to provide responses and has not indicated that

he will provide such information. Since the Plaintiff has refused to respond in a timely manner, the Defendant moves the court to compel the Plaintiff to respond to the Discovery requests.

Motion to Compel - 1 www.NorthwestRegisteredAgent.com

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Dated this 20th day of December, 2009.

Attorney Address Address

Motion to Compel - 2 www.NorthwestRegisteredAgent.com

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