Motion for Contempt Citation, Sanctions and Dispositive Relief

UNITED STATES DISTRICT COURT

FOR A SAMPLE DISTRICT

________________________________

) Case No.:

_______________, )

Plaintiff, )

)

v. )

)

_______________, )

Defendant )

________________________________)

Moving Party: ____________________

Responding Party: _________________

MOTION FOR CONTEMPT CITATION, SANCTIONS

AND DISPOSITIVE RELIEF¹

The Moving Party, _____________, by and through his [her] attorneys, hereby requests that this honorable court issue its order citing the Responding Party for contempt, striking his [her] Complaint and entering a judgment of dismissal with prejudice [or, striking his Answer and entering a default judgment], which order should include an award of costs and attorney fees for the following reasons:

1. The Moving Party did, pursuant to applicable court rules, submit a First Set of Interrogatories to the Responding Party on ____________, 20 __.

2. The Moving Party responded to the interrogatories on _________, 20 __. However, the answers were evasive, incomplete and otherwise deficient as more particularly described hereunder.

3. Both as a matter of courtesy and for the purpose of complying with applicable court rules, your undersigned attorney did prepare and submit to the Responding Party a detailed report setting forth the deficiencies with respect to the answers. Opposing counsel, however, failed and refused to act in good faith or cooperate, thereby necessitating a motion.

4. Pursuant to the motion filed by your undersigned counsel, this...