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IN THE COURT OF COUNTY, MISSISSIPPI PLAINTIFF VS. CIVIL ACTION NO. 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 , Plaintiff filed Plaintiff's First Interrogatories Request for Admissions and Request for Production of Documents and Things Propounded to Defendant. 2. On Defendant delivered their responses with Defendant objecting to answering Interrogatories Nos. and objecting to all the Request for Production of Documents stating that the interrogatories should not be responded to under Rule 26 of the Mississippi Rule s of Civil Procedure and the Request for Production of Documents should not be produced under Rule 34 of the Mississippi 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 whic h 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 Mississippi Rules of Civil Procedure 37 (4), Plaintiff is entitled to his/her reasonable expenses incurred in obtaining an order-compel ling discovery, 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 Pla intiff 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 . ___________________________________