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MEMORANDUM in Opposition to MOTION to Compel UMG to Produce Chain  Form

MEMORANDUM in Opposition to MOTION to Compel UMG to Produce Chain Form

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let me talk to you about motions to compel a motion to compel is you basically tattling to a judge saying that the other side has not followed the Rules of Civil Procedure when they respond to discovery or if they are abusive in depositions such as directing their client enough to answer a deposition when there's no privilege articulated we as plaintiffs lawyers must start bringing motions to compel now these motions to compel are hard work they take a lot of time and you never get paid for them even though you ask the court to award you sanctions basically monetary sanctions against the other side that they have to pay you for bringing the motion to compel you rarely get that but that's not the point in bringing a motion to compel the point in bringing a motion to compel is alerting the defense attorney on the other side that you're a good lawyer you understand the law you understand the rules and you're gonna make them follow those rules and the law as the case unfolds it's important

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