Fill and Sign the State of Alabama Revised 3508 Case No Form

IN THE CIRCUIT COURT OF _______ COUNTY, ALABAMA ___________________ **Plaintiff,**vs. *CIVIL ACTION NO.:*_________________________, *CV-______et al., **Defendants.* PLAINTIFF=S MOTION FOR SANCTIONS PURSUANT TO ALA.R.CIV.P. 37(B) COMES NOW Plaintiff, __________________, by and through counsel, and moves this Court for an Order imposing sanctions on Defendant, ________________ (hereinafter A_______@), and in support hereof Plaintiff does state as follows:1.Plaintiff filed a Motion to Compel _______ to respond to certain discovery requests that the Plaintiff had filed with her Complaint and which had been served on the Defendant. _______ responded with numerous objections and/or incomplete answers making the Motion to Compel necessary.2. Plaintiff=s Motion to Compel was filed with this Court on August 17, 1998.3.After a hearing was held on September 10, 1998 (wherein oral argument was presented by both parties), this Court granted Plaintiff=s Motion to Compel. This Court =s Order was dated September 10, 1998.4.Plaintiff did not immediately seek the documents that the Court ordered the Defendant to produce, given statements of the Court during the hearing that the Plaintiff would be entitled to this discovery if the Plaintiff survived summary judgment. -2- 5. Summary judgment motions were filed by the Defendants; oral argument was heard on said motions; and this Court denied the motions for summary judgment on December 29, 1998. 6.It is now two and one-half (22) months since the summary judgment denials, and Plaintiff has not received these documents as ordered by this Court on September 10, 1998.7.Per Plaintiff= s counsel=s files and confirmation from the _______ County Circuit Court Clerk=s docket sheet, Defendant _______ has not filed a Motion for Reconsideration or similar type pleading as Defendant_______ has done. WHEREFORE, the Plaintiff respectfully requests that this Court enter sanctions against the Defendant, ________________, for said Defendant=s refusal to obey this Court =s Order of September 10, 1998, and assign such sanctions as this Court deems appropriate. JOHN DOE & ASSOCIATES, P.C.Attorneys for PlaintiffPost Office Drawer ____Mobile, Alabama _____(334) __________BY:______________________________________Plaintiff=s counselCounsel=s number -3- CERTIFICATE OF SERVICE I hereby certify that I have on this _____ day of March, 1999, forwarded a copy of the foregoing by United States Mail, first class postage prepaid, and properly addressed to the following:Defense counsel______________________________Plaintiff=s counsel