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- Discovery
Motion to Compel Discovery (State)
CERTIFICATE OF CONFERENCE
On the _____ day of ________________, 20___, a conference was held/attempted with __________________, attorney for the opposing party, regarding the merits of this Motion. Agreement could not be reached; therefore, this Motion is presented to the Court for a determination.
___________________________________
Attorney
_____________’S MOTION TO COMPEL AND FOR
SANCTIONS AGAINST
COMES NOW _______________________________________ (hereafter “Movant”) in the above-referenced matter and files this Motion to Compel Production and for sanctions against ______________________ (hereafter “Respondent”) and would show the Court as follows:
Respondent was served with Interrogatories and Requests for Production of Documents (hereafter “the discovery”). According to the Texas Rules of Civil Procedure, answers to the discovery should have been produced no later than _______________.
On _________________, 20____, Respondent was served with a Notice of Intent to Take Oral Deposition requesting documents responsive to those requests, and on ________________, 20___, Respondent was served with the Notice of Intent to Take Oral Deposition Duces Tecum of _______________, once again requesting the production of these documents.
Movant has asked, both orally and in writing, for the requested information and the production of the requested documents (see Exhibit “A”).
As of the date of the filing of this Motion, Respondent has failed to furnish full and complete answers/documents to many parts of the discovery.
Respondent has objected to some of the discovery. Respondent has not objected to most of the discovery, yet Respondent has failed to provide complete answers.
Respondent’s failure to provide full and complete answers to the discovery and to provide the requested documents is particularly frustrating and inexcusable, given these requests involve basic information necessary to prepare this dispute for mediation.
Further, the documents and information requested are essential so that the Movant can evaluate Respondent’s case. Without this information, Movant will not have any basis for understanding Respondent’s claims.
Therefore, Movant asks this Court to order the Respondent to:
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Answer Interrogatory No. ___ fully and completely.
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Answer Interrogatory No. ___ fully and completely.
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Answer Interrogatory No. ___ fully and completely.
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Answer Interrogatory No. ___ fully and completely.
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Answer...
To continue reading
Request your trial- Appendices
- Discovery
- Deposition Checklist: Deposing the Plaintiff in Employment Cases (In General)
- Deposition Outline Checklist: Plaintiff’s Deposition of Defendant’s Employees: General Questions
- Deposition Duces Tecum Propounded to Defendant City, Whistleblower Case
- Oral and Video Deposition Duces Tecum Propounded to Defendant for Employment Cases in General
- Oral and Video Deposition Duces Tecum to Plaintiff for Employment Cases in General
- Scholastic Records Authorization
- Military Records Authorization
- Medical records authorization
- Employment Records Authorization
- Authorization for Texas Worker’s Compensation Commission Records
- Deposition outline (plaintiff)-false imprisonment
- Plaintiff's first request for production of documents propounded to defendant city in a whistleblower case
- Plaintiff's "triple threat" discovery to defendant in age discrimination case
- Sworn Statement by Non-Managerial Employee of Defendant
- Defendant's "triple threat" discovery propounded to plaintiff employee's spouse
- Defendant's "triple threat" discovery propounded to plaintiff in employment cases in general
- Standard instructions and definitions for plaintiff's written discovery to defendant
- FOIA Request to the EEOC
- Standard Instructions and Definitions for Defendant’s Written Discovery to Plaintiff
- Plaintiff's "triple threat" discovery propounded to defendant in sexual harassment case
- Standard Responses, Objections, and Answers to Interrogatories For Defendants and Plaintiffs
- Standard responses, objections and answers to request for production of documents for both defendants and plaintiffs for federal court cases only
- Plaintiff's standard "triple threat" discovery to defendant in employment cases in general
- Level Three Discovery Control Plan
- Request for disclosures (long format) (state)
- Deposition outline-economist
- Deposition outline-medical/mental health professional
- Standard Responses, Objections, and Answers to Interrogatories for Defendants and Plaintiffs Under Texas Rules of Civil Procedure
- Standard Responses, Objections and Answers to Request for Production of Documents for Defendants and Plaintiffs Under Texas Rules of Civil Procedure
- Request for disclosures (short format) (state)
- Motion to Compel Discovery (State)
- Open Records Request to the TCHR
- Plaintiff's proposed pattern interrogatories and request for production
- Authorization for Release of Financial Records
- Discovery Plan
- Defendant's first set of requests for production to plaintiff-FLSA
- Petition Requesting Deposition Before Suit
- Plaintiff's "triple threat" discovery to former employee stealing trade secrets
- Opposition to Pre-Suit Deposition
- Plaintiff's "triple threat" discovery to defendant - sexual harassment
- Sexual Harassment and FirinG
- Plaintiff's Triple-Threat to Defendant re: Stealing Trade Secrets
- Race, Age and Firing-Short Version
- "About Your Upcoming Deposition"
- Request For Disclosure To Defendant-FMLA, ADEA
- Deposition outline-corporate representative-products liability
- Order Authorizing Deposition
- Defendant's First Set of Interrogatories to Plaintiff-FLSA
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