Fill and Sign the Motion Compel Discovery Form

STATE OF MINNESOTA DISTRICT COURT COUNTY OF             JUDICIAL DISTRICT FAMILY COURT DIVISION In Re the Marriage of: Court File No.             , Petitioner, NOTICE OF MOTION AND MOTION AND TO COMPEL DISCOVERY       , Respondent, TO: _____________ , _____________ ABOVE-NAMED, BY AND THROUGH (HIS) (HER) ATTORNEY, _____________ , ______________________________________ . YOU WILL PLEASE TAKE NOTICE that on the       day of _____________ , 20       , at       :             .m., or as soon thereafter as counsel may be heard before the Honorable _____________________________ , a (Referee)(Judge) of the above-named Court, at the _____________ County (Government Center)(Courthouse), _____________________ , in the City of _____________ , County of _____________ , and State of Minnesota, _____________ herein will move the Court for an Order: 1 . Compelling _____________ to provide complete Answers to _____________ 's Interrogatories, which were served (personally) (by mail) on ( _____________ ) ( _____________ 's attorney) on _____________ , 20       . 2 . Compelling _____________ to produce all of the documents requested in _____________ 's Request for Production of Documents, which were served (personally) (by mail) on ( _____________ ) ( _____________ 's attorney) on _____________ , 19__. - 1 - - 2 -3 . Establishing for purposes of this action that any information requested in _____________ 's Interrogatories and Request for Production of Documents shall be in accordance with the claims of _____________ if _____________ fails to provide complete answers to _____________ 's Interrogatories and complete responses to _____________ 's Request for Production of Documents within thirty (30) days. 4 . Prohibiting _____________ from supporting claims in opposition to _____________ with information or evidence that should have been provided in response to _____________ 's Interrogatories and Request for Production of Documents if complete answers to _____________ 's Interrogatories and complete responses to _____________ 's Request for Production of Documents are not provided by _____________ within thirty (30) days. 5 . Finding that if _____________ does not provide complete answers to _____________ 's Interrogatories and complete responses to _____________ 's Request for Production of Documents within thirty (30) days, a request by _____________ for a default judgment against _____________ should be considered. 6 . Requiring _____________ to pay to _____________ the sum of _____________ ($       ) as and for reasonable attorneys' fees and costs incurred incident to this motion. OR 6. Requiring _____________ to pay to _____________ a reasonable sum as and for attorney's fees and costs incurred incident to this motion. 7 . For such other and further relief as the Court may deem just, fair and equitable in the premises. SAID MOTION is based upon the Affidavit of _____________ , _____________ 's Rule 303.03(c) Certification of Settlement Efforts, and arguments of counsel, together with all pleadings, records and files herein, and Minn. R. Civ. P. 37. - 3 -Dated: Name:       Title:       Address:       Address:       City, State, Zip:       Phone:       Fax:       E-Mail:       Attorney Reg. No.: