Motion for Partial Summary Judgement by Plaintiff

UNITED STATES DISTRICT COURT

FOR A SAMPLE DISTRICT

______________________________

) Case No.:

Peter Plaintiff, )

Plaintiff, )

)

v. )

Donald Defendant, )

Defendant. )

______________________________)

Movant: __________

Respondent: __________

MOTION BY PLAINTIFF

FOR PARTIAL SUMMARY JUDGEMENT

FOR DEFENDANT’S FAILURE

TO COMPLY WITH DISCOVERY ORDER

The Plaintiff Movant, __________, by and through his attorneys, hereby requests that this honorable court issue its order granting the Plaintiff a partial summary judgement for a repeated failure by Defendant to comply with the Plaintiff’s Notice for Production of Documents and Defendant’s failure to comply with the court’s order in that regard, and the Plaintiff further requests that this court impose sanctions upon the Defendant by requiring him to pay to the Plaintiff those reasonable costs and attorney fees incurred by Plaintiff with respect to this motion. The basis for this motion is as follows:

1. The Plaintiff, in accordance with the court applicable rules, submitted a Notice for Production to the Defendant on _____, 20__ requesting the production of __________ at the offices of __________ located at __________.

2. The requested items are contained within the Notice for Production and in the Motion to...