FOR THE NORTHERN DISTRICT OF ILLINOIS
JUSTIN WILLIAM KING,)
ANHEUSER-BUSCH COMPANIES, INC.,)
MOTION TO COMPEL DISCOVERY
Pursuant to Rule 37 of the Federal Rules of Civil Procedure and any applicable Local Rules of the United State District Court for the Northern District of Illinois, Defendant, by its counsel, moves this court for the entry of an order compelling the Plaintiff to fully comply with the Defendant’s discovery requests and cure the discovery deficiencies within fourteen (14) days of the order.
In further support of the above, Defendant states:
1.Interrogatories were served on March 11th, 2013.
2.The Plaintiff's Responses to the interrogatories were due no later than April 10th, 2013. To date, no Response has been received.
3.A good faith effort has been made to recover the Plaintiff's Responses. On March 25th, 2013, counsel for the Defendant requested in writing to Plaintiff's counsel for a response, noting that if responses were not received by April 10th, 30 days after service of Interrogatories, a Motion to Compel would be filed. On April 1st, 2013, a phone message was left with Plaintiffs counsel asking for Responses. No return call was received.
4.The Plaintiff has refused to provide responses and has not indicated that he will provide such information. Since the Plaintiff has refused to respond in a timely manner, the Defendant moves the court to compel the Plaintiff to respond to the Discovery requests. Defendant further respectfully request that the Court enter an order of sanctions taxing in their favor and against the Plaintiff’s counsel the Defendant’s reasonable attorney's fees and other expenses incurred in obtaining the entry of an order compelling the discovery sought in this proceeding....