Request again that the other side respond to your discovery: “The items listed in Exhibit A are requested again by this motion.Defendant, however, has not responded to this request.” When that happens, a party can file a motion to compel, asking the Court to order the opposing party to produce the contested documents or information. An example of how the discovery chart should be completed is attached to. This letter requested that Defendant answer the Interrogatories within two weeks’ time. Discovery requests that are subject to a motion to compel or a motion for. “On February 22, 2016, Plaintiff send Defendant a letter by certified mail, return receipt requested. 1 Memo Points and Authorities ISO Motion to. Also mention that you have attached a copy of the letter as an exhibit. memorandum of points and authorities in support of motion to compel.
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