![]() ![]() A copy of these letters are attached as Exhibits B and C. That on March 2, 2017, the attorney representing the Plaintiff requested that all Defendants supply Answers to Interrogatories and responsive documents.A copy of this letter is attached Exhibit A. That on February 15, 2020, the attorney representing the Plaintiff requested that Defendant Erie supply Answers to Interrogatories and responsive documents.The undersigned counsel for the Plaintiff certifies that counsel for the above parties have been unable to reach an agreement concerning this dispute, and as reasons, state: 24-C-04-008432 MT Certificate of Good Faith Attempts to Resolve Discovery Dispute Certificate of good faith attempts to resolve discovery dispute.ĬASE NO.WHEREFORE, the Plaintiff moves for an Order compelling the Defendants to produce complete and executed Answers to Interrogatories and the required documents within the next 15 days.Īttorney for the Plaintiff Statement of Grounds and Authorities Plaintiff just wants answers so we can proceed with the litigation without delay. Plaintiff is not looking for a court order for sanctions or fees. That to date, Plaintiff has not received responses to our discovery requests from any of the Defendants in this matter.That on March 2, 2020, the Plaintiff requested, by way of a letter address to all Defendants’ counsel, that the Answers to Interrogatories and Response to the Request for Production of Documents be promptly supplied.That on February 15, 2020, the Plaintiff requested, by way of a letter addressed to Defendant Erie's counsel, that the Answers to Interrogatories and Response to the Request for Production of Documents be promptly supplied. ![]() That discovery in the form of Interrogatories and Request for Request for Production of Documents were served in this case on Defendant Kennedy on January 8, 2020.That discovery in the form of Interrogatories and Request for Production of Documents were served in this Maryland car accident case on Defendant Davis on December 15, 2019.Miller, Jr., moves pursuant to Maryland Rule of Procedure 2-432 for an Order compelling the Defendants, Steven Kennedy, Michael Davis, and Erie Insurance Exchange, to promptly produce all outstanding discovery, and in support, states as follows: The Plaintiff, Mandy Glenn, by her attorney, Ronald V. IN THE CIRCUIT COURT FOR BALTIMORE CITY, MARYLANDĬASE NO. Too many defense lawyes think discovey is due after a motion compelling it gets granted. This is the most common discovery motion we file. Below is a sample motion to compel discovery.
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