Fill and Sign the Motion to Compel Answers to Interrogatories and Plaintiffs Request for Production Louisiana 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. _______ _____________ and : _______ JUDICIAL DISTRICT COURT _____________ : PARISH OF _______ , LOUISIANA _____________ : DOCKET NO. _______ _____________ ______________________________________________________________________________ __ ORDER Considering the foregoing Motion, IT IS ORDERED THAT Defendant, _____________ , show cause on the __________ day of ____________________, 20____, at ________ o'clock ___.m., why judgment should not be rendered in favor of Mover, by default, on account of failure to make discovery, or why the Court should not enter an order that the interrogatories be answered and documents be produced within a time specified by the Court, under penalty of default; and further why Mover should not have judgment for reasonable attorney's fees and for all costs and expenses for bringing this Motion. _____________ , Louisiana this __________ day of ____________________, 20____. ______________________________ DISTRICT JUDGE Sheriff, please serve: _____________ Defendant - in - rule Through its attorney of record _____________ Attorney at Law _____________ _______ , LA _______ CERTIFICATE I HEREBY CERTIFY that a copy of the above and foregoing pleading has been forward by U.S. Mail to _____________ , Attorney for Defendant, _____________ , LA _______ , postage prepaid and properly addressed. _____________ , Louisiana this ______ day of _____________________, 20____. _____________________________ _____________