IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
) Civil Action No. 11-CIV-012345
Anheuser - Busch
) Judge Julie James
MOTION TO COMPEL DISCOVERY
Pursuant to Rule 37 of the Federal Rules of Procedure, the Defendant in this case, Anheuser-Busch, 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. In this action, the Defendant served Plaintiff written interrogatories on April 30th 2013. This written discovery was served by hand-delivery.
2. Defendant believes that by the Plaintiff not complying with the discovery request as requested that the Plaintiff be found in contempt for not answering the following interrogatories:
1. Does Mr. King have a mental problem?
2. Was Mr. King wearing a DOT approved helmet?
3. Does Mr. King have a drug dependency problem?
4. Was Mr. King on any prescribed medication at the time of the accident?
5. Why did Mr. King turn into the truck instead of away from the falling cargo as alleged?
WHEREFORE, pursuant to Rule 37 of the Federal Rule of Procedure, the Defendant moves this court for the entry of an order compelling the Plaintiff to provide discovery responses to cure the above-listed deficiencies within fourteen (14) days. 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. Defendant further respectfully requests such other...
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