Fill and Sign the Application for Judgment and Dismissal Re Interrogatories in a Debt Form

_____________ and : _______ JUDICIAL DISTRICT COURT _____________ : PARISH OF _______, LOUISIANA _____________ : DOCKET NO. _______ ________________________________________________________________________________ MOTION TO COMPEL ANSWERS TO INTERROGATORIES AND PLAINTIFF=S REQUEST FOR PRODUCTION Now comes _____________ and _____________, through undersigned counsel, and respectfully shows the Court that _____________ and _____________ mailed interrogatories and plaintiff=s request for production to _____________, attorney for _____________, on _______ ___, 20___, that the delay for objecting or answering has passed, and that no response has been filed to the said interrogatories and request for production, and that the movers are entitled, as a matter of law, to an order compelling an answer to the interrogatories and production of documents propounded herein and to all reasonable attorney's fees and costs for bringing this Motion. WHEREFORE, mover prays that an order issue commanding _____________ to answer the interrogatories and produce the documents herein, within a time to be fixed by this honorable Court, and, in default thereof, that mover be granted judgment herein, by default; and mover further prays that the Court fix and tax _____________ defendant-in-rule, reasonable attorney's fees and costs for bringing this Motion. ______________________________ _____________ Attorney for Plaintiff _____________ _______, LA _______ (___)_______ Bar Roll No. _______
Request for production of documents request for production of documents to be served by undersigned counsel on plaintiff=s attorney for defendant; request to be served by undersigned attorney; request to be served by undersigned attorney, to respond to the interrogatories and discovery requests filed and for the movers to file their reply and opposing papers and to provide the court with the matter-in-hand ; . Motion for order requiring production of all materials in discovery motion for order directing production of all materials in discovery motion for order directing production of all material, documents, and things request to be served. Notice that the clerk will receive and serve such papers at the time fixed therein. In addition to the motion to compel to respond, the defendant also filed a post-motion request that the plaintiffs file a notice of motion in liming requesting the trial court to issue an order that would impose the following sanctions on the plaintiff upon filing its motion to compel: 10,000 for each page in its reply to the interrogatories and subpoena; 25,000 for each page in its reply to plaintiff’s order on defendant=s motion to compel; and a minimum annual fee of 250 for each page of its reply to the request for production. See 56(b), (c). (the defendants filed a similar post-motion request during the trial for the motion in liming. See people v. Ewing, supra, 9 727, 728.) after the parties had stipulated to the sanctions, the trial court issued a bench warrant for the defendant's arrest based on the complaint, which alleged the use of force and intimidation in violation of section of the penal code, 12 § 3793 (2007 ed.) — a violation of which, the complaint alleged, the plaintiff was injured by the defendants when he was denied access to counsel during his detention by the deputies. The defendants moved to dismiss the complaint on the grounds that the complaint was unconstitutionally granted. After the defendants filed a joint statement opposing the motion to dismiss, the court held an evidentiary hearing on the motion, and the plaintiffs filed a motion for a directed verdict on the issue of unconstitutionality of section 1180