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Attorney 123 Main Street Anytown, US 12345

DISTRICT COURT OF ___________________

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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.

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Dated this 20th day of December, 2009.

Attorney Address Address

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