Fill and Sign the Motion to Compel and for Attorneys Fees and Expenses Form

- 1 - IN THE ______________ COURT OF ______________ COUNTY STATE OF ________________ ) ) ) Petitioner/Plaintiff, ) ) ) NO. Vs. ) ) ) Respondent/Defendant ) ) MOTION TO COMPEL AND FOR ATTORNEY'S FEES AND EXPENSES COMES NOW Plaintiff, __________________________, and moves the Court for an Order compelling response to Interrogatories and Request for Production of Documents directed to Defendant and for attorney's fees and expenses incurred in bringing said Motion, and in support thereof would show unto the Court as follows: 1. On or about _______ 20___, Plaintiff filed Plaintiff's First Interrogatories Request for Admissions and Request for Production of Documents and Things Propounded to Defendant. 2. On ________ 20___ Defendant delivered their responses with Defendant objecting to answering Interrogatories No. 4, 5, 6, 7, 8, 10, 11, and 13 and objecting to all the Request for Production of Documents stating that the interrogatories should not be responded to under Rule ______of the ____________ Rules of Civil Procedure and the Request for Production of Documents should not be produced under Rule ______ of the ____________ Rules of Civil Procedure. 3. Plaintiff would show unto the Court that the Interrogatories ask and the Request for Production of Documents are calculated to lead to the discovery of evidence which is relevant to the issues raised by the claims set forth in this cause. And the Defendant's failure to response to discovery is inappropriate. 4. Plaintiff has incurred expenses in bringing this Motion to Compel, which was necessitated by the conduct of the Defendant. Under ____________ Rules of Civil Procedure ______(4), Plaintiff is entitled to his reasonable expenses incurred in obtaining an order compelling discovery, - 2 - including attorney's fees.WHEREFORE, PREMISES CONSIDERED, Plaintiff, moves this Court for an Order compelling the Defendant to respond to the aforementioned discovery and awarding the Plaintiff attorney's fees and expenses in an amount as the Court may deem proper and just in bring said Motion to Compel. Respectfully submitted, this the ________ day of ________ 20________. __________________________ __________________________ CERTIFICATE OF SERVICE I, ________________, attorney for Plaintiff, does hereby certify that I mailed, U. S. postage prepaid, a true and correct copy of the above and foregoing Motion to Compel to This the ______ day of ___________ 20______. ________________________