Occasionally in vision injury cases, as with all other injury litigation, it becomes necessary to file a motion to compel the other side to produce the information you are entitled to. Here is a sample motion to compel that I hope will help you. If you need more help, give me a call at 610 642 7676.
EVAN K. AIDMAN, ESQUIRE ATTORNEY FOR PLAINTIFF
Identification Number 38746
1420 Walnut Street
Suite 808
Philadelphia, PA 19102
(215) 563-7088
____________________________________________________________________
AXEL DENT Court of Common Pleas
v.
DEE FENDANT Philadelphia County
MOTION TO COMPEL DISCOVERY
Plaintiff, by undersigned counsel, hereby moves the Court to enter an Order pursuant to PA. R. C. P. 4019 compelling defendant to answer certain discovery propounded by plaintiff in this matter. In support of this Motion, plaintiff avers:
1. On November 3, 2009 plaintiff served Interrogatories and Requests for Production of Documents upon counsel for defendant by first class mail.
2. Pursuant to PA. R. C. P. 4006(a)(2), defendant’s answers and objections to the said Interrogatories and Requests were due on or before December 3, 2009.
3. Plaintiff requires an Order of this Court pursuant to PA. R. C. P. 4019(a)(1)(i) compelling defendant to answer the said Interrogatories and to respond to the said Requests for Production of Documents.
WHEREFORE, plaintiff respectfully requests that the Court enter the attached Order.
EVAN K. AIDMAN, ESQUIRE
Attorney for plaintiff
EVAN K. AIDMAN, ESQUIRE ATTORNEY FOR PLAINTIFF
Identification Number 38746
1420 Walnut Street
Suite 808
Philadelphia, PA 19102
(215) 563-7088
____________________________________________________________________
AXEL DENT Court of Common Pleas
v.
DEE FENDANT Philadelphia County
ORDER
AND NOW, this day of , 2013, upon consideration of plaintiff’s Motion to Compel Discovery, it is hereby ORDERED that the said Motion is GRANTED. Defendants shall answer plaintiff’s Interrogatories and respond to plaintiffs’ Request for Production of Documents within twenty (20) days of the date of this Order or appropriate sanctions shall be imposed upon defendant following application to the Court. All documents produced or withheld are to be numbered consecutively beginning with the number one.
BY THE COURT:
_____________________________
J.
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