DeAnna Douglas

Week 8 Assignment 8.4

LGA4000XA
1 hour 33 minutes

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF COLUMBIA
Ms. Rakowski
Plaintiff,
v.
Carlos Montez
Defendant,

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No. 04 C 1010
MOTION TO COMPEL

MOTION TO COMPEL
Plaintiff moves for an order-compelling defendant to answer and produce relevant
documents from the interrogatories previously served on the defendant, pursuant to Rule 37 of
the Federal Rules of Civil Procedures. In support of her motion the plaintiff states:
1. Plaintiff served interrogatories on defendant July 10, 2015.
2. Defendant partially answered these interrogatories and objected to produce reports of
previous incidents of harassment. He has objected on the grounds that this is irrelevant.
3. Plaintiff has relevant standing for all pervious harassment reports to be entered as
tangible evidence.
4. These side documents would help the plaintiff in her claim of work place harassment.
WHEREFORE, plaintiff requests the court order the defendant to sever answers to the
interrogatories within ten days, and send copies of previous documentation of harassment.
Dated: November 25, 2015
White, Wilson & McDuff
Attorney for Plaintiff
Federal Plaza Building, Suite 700
Third and Market Street
Legalville, Columbia 00000

DeAnna Douglas
Week 8 Assignment 8.4
LGA4000XA
1 hour 33 minutes

AFFIDAVIT OF SERVICE
I William White, having been first duly sworn, state that I have served a copy of the
attached Motion to Compel Discovery on defendants attorney by mail at 100Congrss Street
Legalville, Columbia 00120, on November 25, 2015.

William White
Signed and sworn to before me on November 25, 2015.

Notary Public
My Commission expires on December 31, 2023.
[Seal]