ABOUT THIS FORM
This is a sample Motion to Compel Discovery filed in an auto accident case in Baltimore City Circuit Court. Interrogatories and RPDs were served and a follow up letter was sent to defense counsel, but no responses were ever received.
IN THE CIRCUIT COURT OF MARYLAND
FOR BALTIMORE CITY
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PLAINTIFF’S MOTION TO COMPEL DISCOVERY
Now Comes Jonathan Smith, Plaintiff herein, by and through his attorneys, Rodney M. Gaston and Miller & Zois, LLC, and hereby moves that the Defendants be compelled to submit responses to the Plaintiff’s discovery requests and in support thereof states as follows:
CERTIFICATE OF GOOD FAITH ATTEMPTS
TO RESOLVE THE DISCOVERY DISPUTE
I, Rodney M. Gaston, hereby certify that on November 19, 2018, November 30, 2018 and December 10, 2018, I mailed letters to defense counsel requesting that the Defendants submit their discovery responses. These letters are attached hereto as Exhibit 2. That as of this date, neither Defendant has submitted duly executed Answers to the Plaintiff’s Interrogatories, nor has either Defendant submitted Responses to the Plaintiff’s Request for Production of Documents and the parties are unable resolve this discovery dispute and need assistance from the Court.