Casetext, Inc. and Casetext are not a law firm and do not provide legal advice. Motion To Compel Discovery Law and Legal Definition Opposition to Motion to Compel Discovery M. STEWART RYAN, ESQUIRE 1:6-3 (a) (amended eff 4/25/22). 127, 131 (App. Former rule deleted and new R. 4:23-1 adopted July 14, 1972 to be effective September 5, 1972; paragraphs (a) and (c) amended July 13, 1994 to be effective September 1, 1994; paragraph (a) amended July 5, 2000 to be effective September 5, 2000. If you cannot open a file, try " right clicking ". A-2539-18T2, at *18 (App. TAMARRIA BARLOW and SUPERIOR COURT OF NEW JERSEY 1985). The contact form sends information by non-encrypted email, which is not secure. 549, 553. Dec. 28, 2012). <<95ad678d1b862b4e9402f548802fc4f2>]>> Background After commencement of the action, any party may take the testimony of any 1 of If the motion to compel is granted, the court will, after opportunity for hearing, require the party or deponent whose conduct necessitated the motion to pay to the However, defendant Elizabeth Rummel suffered a stroke and could not attend. The return date is also the date on which the court will consider the motion, either on the papers or with oral argument. Right to Enforce Discovery Obligations, or You M. DANIEL CANTOR, ESQUIRE Web) Motion to Compel v. )))) Defendant. ) ), When a requesting party demands access to or copies of papers in an interrogatory, the responding party may decline by stating with specificity the reason for its noncompliance in response to the interrogatory. Please do not include any confidential or sensitive information in a contact form, text message, or voicemail. The failure to act described in this rule may not be excused on the ground that the discovery sought is objectionable unless the party failing to act has applied for a protective order as provided by R. 4:10-3. Too many defense lawyes think discovey is due after a motion compelling it gets granted. If our consideration of the issues was limited to the application of New Jersey law the result would be obvious because N.J.S.A. I also understand that Miller & Zois works with multiple law firms on these claims and that I may be contacted by an affiliated law firm working with Miller & Zois on these lawsuits. by clicking the Inbox on the top right hand corner. A motion to compel against a non-party Zaccardi, supra, 88 N.J. at 252. Defendants thereupon moved to dismiss the complaint. Plaintiff's counsel was again unable to attend. 2 Trans, OCN-L-000480-20 11/08/2021 4:38:14 PM Pg 1 of 1 Trans ID: LCV20212603898 State v. Leonardis, 73 N.J. 360, 368 (1977) (Leonardis II); see also Passaic Cty. 54, 59;Axelrod v. CBS Publications (1982) 185 N.J. Super. 1204 0 obj <> endobj 197 6). The person bringing the motion is called the moving party. Proc. Subpoenas: Enforcing a Subpoena (Federal) - Weil, Gotshal In practice, however, the court often fixes the time to make discovery in orders granting motions to compel irrespective of the basis for the motion. Not a Lexis+ subscriber? ), It is well settled that Rule4:17-1(4) provides, [e]xcept as otherwise provided [e.g., where a claim of privilege is made or where the information is the subject of a protective order,] every question propounded by a uniform interrogatory must be answered unless the court has otherwise ordered.(See Herrick v. Wilson, No. Middlesex County Courthouse BER-L-7317-20, at *7 (N.J. Super. If our consideration of the issues was limited to the application of New Jersey law the result would be obvious because N.J.S.A. If a party or an officer, director, or managing agent of a party or a person designated under R. 4:14-2(c) or 4:15-1 to testify on behalf of a party fails to appear before the officer within this State who is to take his deposition, after being served with a proper notice, the court in which the action is pending on motion may make such orders in regard to the failure as are just, and among others it may take any action authorized under paragraphs (1), (2) and (3) of R. 4:23-2(b). Part IV - Rules Governing Civil Practice in the Superior Court, Tax Court and Surrogate's Courts, Rule 4:23 - Failure to Make Discovery; Sanctions, Rule 4:24 - Time for Completion of Discovery and Other Pretrial Proceedings. We remand for the entry of an order reinstating plaintiff's complaint and fixing of a date certain for the depositions of the parties. July 10, 2018). 9-11-37, 9-15-14 and any other applicable law. xbbe`b``3 1x4>( e Jurisdictional Discovery N.J.R. endobj Hopefully I won't need it again but if I do, I have definitely found my lawyer for life and I would definitely recommend this office to anyone! May 17, 2013). WebA sample certification that a party may file in support of a motion to compel discovery in actions pending in the New Jersey Superior Court, Law Division, Civil Part or the Chancery Division, General Equity Part. q.dgRpB iUN ]Q,)om! LCV20212099327, 1 When taking a deposition on oral examination, the proponent of the question may complete or adjourn the examination before applying for an order. Discovery | District of New Jersey | United States District Court There is no authority for a "local rule" limiting sanctions available to a motion judge for a violation of the discovery rules. The Supreme Court's power to adopt court rules stems from the grant of such authority in N.J. Const. Your content views addon has successfully been added. 4:58:12 PM PgPg1 of1 1ofTrans WebCivil Motion Forms: Superior Court of New Jersey NJ Civil Motion Forms Motions are necessary when a litigant is asking the court to provide specific relief in advance of a trial. N.J.R. 0000003589 00000 n Try it out for free. ), SOM-L-000861-20 (b) Evasive or Incomplete Answer. Motion to Compel Discovery N.J.R. Honorable William J. McGovern III, J.S.C. R. 4:23-4 also provides that in lieu of any order, the court may require the party failing to act to pay the reasonable expenses, including attorneys fees caused by the failure. WebOn motion to compel discovery or for a protective order, the party from whom discovery is sought must show that the information is not reasonably accessible because of undue burden or cost.13 In a best-case scenario, you have legal support in the form of actual case law (preferably from your jurisdiction) supporting your discovery requests. You can always see your envelopes N.J.R. 1978), aff'd 80 N.J. 343 (1979); U.S. R. 5.3(c) for materials 4. Ron even fought to reduce how much I owed in medical bills so I could get an even larger settlement. NJ CIVIL MOTION FORMS at 517, the depositions were adjourned on two occasions because of defendant Elizabeth Rummel's illness. Motion to Compel Discovery Discovery is the process by which the parties to a legal action request and obtain information and evidence from the other parties. ELIZABETH RUMMEL AND WILLIAM RUMMEL, DEFENDANTS-RESPONDENTS. We will email you WebRULE 4:23-1 - Motion for Order Compelling Discovery. Morris County Civil Divisio, BUR L 000076-21 09/15/2021 Pg 1 of 1 Trans ID: LCV20212147633 !k')O '=4$!=JnkJfUN-[v^U(u|Qv,% `IHkG?6B@I_K9'w` l. try clicking the minimize button instead. Don't ask for attorney's fees unless the discovery violations are extreme and especially don't ask for "reasonable expenses" for drafting a template motion like this when the responding party has not provided any response at all. 0 WebSample Motion to Compel Discovery. WebPRACTITIONERS GUIDE TO NEW JERSEYS CIVIL COURT PROCEDURES PRACTITIONERS GUIDE TO NEW JERSEYS CIVIL COURT PROCEDURES UPDATED AS OF JANUARY 2011 NEW JERSEY INSTITUTE OF CONTINUING LEGAL EDUCATION One Constitution Square, New Brunswick, N.J. 08901-1520 (732) 249-5100 when new changes related to "" are available. Rule 1:6 - Motions and Briefs in the Trial Courts. September 15, 2021 ~?O_"uIhx;mzBzv6Nz*=%FQ77i0ZIJo9;. 4:24-1 (c) (amended eff 9/1/18). must be made returnable prior to the expiration of the discovery period.(See Carbis Sales v. Eisenberg (2007) 397 N.J. Super. Thomas D. McCloskey In this personal injury action, plaintiff appeals from an order dismissing her complaint for failure to attend a deposition. 4:23-1(c). 582, 586 (Law Div. (c) Award of Expenses of Motion. The motion was denied because of a "local rule" that the appropriate motion when a party fails to attend a deposition is for dismissal of the complaint or suppression of the answer, rather than to fix a date certain for the deposition. Direct Dial: (215) 400-2845 . Superior Court of New Jersey, Appellate Division. Ct. Part I. We must therefore assume, as do the parties, that the order of dismissal was entered, at least in part, because of the motion judge's adherence to the "local rule." endstream endobj 649 0 obj[3[250 333]36[722]38[722 722 667 611 778 778 389 500 778 667 944 722 778]53[722 556 667 722 722 1000]60[722]177[500]179[500 500]182[333]] endobj 650 0 obj<> endobj 651 0 obj<>stream 0000001736 00000 n *16 Before Judges COLEMAN, HAVEY and STERN. On appeal plaintiff contends that the "local rule" circumscribes judicial discretion in the disposition of discovery motions under the Rules Governing Civil Practice. If you have been injured in a nursing home or 8 1:1-3. 1:4-5. Motion to Compel Discovery Sample Document - Free 0 0000001343 00000 n (c) Motion to Compel. FIRST JUDICIAL DISTRICT OF PENNSYLVANIA PHILADELPHIA Except as provided in 7:8-9A, if without just excuse or because of failure to give reasonable attention to the matter, an application is made for an adjournment, the court may order the payment of costs and expenses by the party applying for adjournment. ROSE CUNNINGHAM, PLAINTIFF-APPELLANT, N.J.R. L-1913-10, at *3 (Law Div. Your subscription was successfully upgraded. R.4:17-5(b).When a responding party declines to turn over requested If the delinquent party fails to comply by this date, the aggrieved party may file a motion for dismissal or suppression. N.J.R. ), It is also well settled that R. 1228 0 obj <>/Filter/FlateDecode/ID[<5D648DF4CF0B8D4198F297B63189C2D3>]/Index[1204 61]/Info 1203 0 R/Length 117/Prev 414673/Root 1205 0 R/Size 1265/Type/XRef/W[1 3 1]>>stream Email: gsellers@klehr.com 3. Here, adherence to the "local rule" was such an injustice. Civil Procedure Rule 37: Failure to make discovery: Sanctions Pleadings, motions and briefs must be signed and dated by the attorney of record or the attorney's associate or by a pro se party. Here is the reason: To view this free sample motion to compel discovery, click the link below. Copyright RPCD Holdings LLC 2003-2023 exclusive of the text of government codes. cy] Sign up for our free summaries and get the latest delivered directly to you. October 20, 2021 ;{ q1QH5>?E{?Zl?im!Z_I[jpA?~K?pyiTDcBxN D&,,}6lGLxV [oG\Pcy7xER%='(^'0 : MER-L-002124-19 startxref VIA E-COURTS MID-L-005163-18 10/20/2021 2:50:55 PM Pg 1 of 1 Trans ID: LCV20212441516 His motion was clearly proper *20 under R. 4:23-4. Plaintiff's counsel refused to produce plaintiff at the depositions. A local court has no authority to promulgate rules which abrogate or modify the rules promulgated by the Supreme Court. We therefore reverse and remand for further proceedings. Defendants had moved for an order to set a date certain for the taking of the deposition. Rule 4:23-2. 638 0 obj<> endobj 79 N.J. 464 (1978) (Zaccardi I). This rule-making authority "has also been widely recognized as falling within court's inherent powers." Award of Expenses of Motion. Here, dismissal of the complaint, predicated at least in part on the "local rule," was an abuse of discretion. Lawrenceville, NJ 08648 1 0 obj 1:6-2 (e) (amended eff 9/1/22). Webshall assign the Discovery Motion a control number. The undersigned counsel for the Plaintiff certifies that counsel for the above parties have been unable to reach an agreement concerning this dispute, and as reasons, state: Sample Motion to Compel Discovery | Maryland Personal Injury Lawyer. N.J.R. Except as provided in 7:8-9A, if without just excuse or because of failure to give reasonable attention to the matter, no appearance is made on behalf of a party on the return of a motion, the court may dismiss or grant the motion or application, continue the hearing to the next motion day or take such other action as it deems appropriate. And please don't file for a default judgment. v. Francis (1975)133 N.J. Super. 1:6-2 (a) (amended eff 9/1/22). UtjrZ^Kkh. 37(a)(3) and Local Rule 3.04, Plaintiff moves the Court to compel Defendants to respond to Interrogatories 2 October 19, 2021 Discovery and calendar motions are considered on the papers unless, on at least 2 days' notice before the return date, the court specifically directs oral argument. WebThis matter comes before the Court upon the Motion of Defendant, Wal-Mart Corporation (Wal-Mart), seeking an Order to Seal pursuant to L. Civ. 640 0 obj<>stream Motion to Compel Discovery - New Jersey Bergen Superior (Plaintiffs' lawyers should always file discovery and deposition notices with the complaint.). It was his view that all of the parties should be deposed together "in the interest of efficiency.". 01/10/2022 &@:yXQA)o2`\t&iWz 1264 0 obj <>stream N.J.Sup.Ct., 205 N.J. Super. Adding your team is easy in the "Manage Company Users" tab. If a deponent fails to answer a question propounded or submitted under R. 4:14 or 4:15, or a corporation or other entity fails to make a designation under R. 4:14- 2(c) or 4:15-1, the discovering party may move for an order compelling an answer or designation in accordance with the request. ), Or, (2) to permit entry upon designated land or other property in the possession or control of the party upon whom the request is served for the purpose of inspection and measuring, surveying, photographing, testing or sampling the property or any designated object or operation thereon, within the scope ofR.4:10-2. (See Id. A motion to compel disclosure or discovery pursuant to Rule 37 must be brought in the court where the action is pending. Too many defense lawyes think If the specification is so broad and indefinite as to be oppressive and in excess of the defendant's necessities, then the Motion should be denied.(See Min Wu v. Jafco Foods, Inc., No. If a party has chosen to file a motion to compel where there has been complete failure to make written discovery or submit to examinations, any order granting that motion will specify the date by which compliance is required. endobj ]:ZnR]BK7H!7-5E69A;w tn M7|$ftAVznmzoFO y~?F.z y+=,IOO'9?E3uH9?C~_W,= Your alert tracking was successfully added. You can explore additional available newsletters here. How to File a Motion - Law Division - Civil Part ), Rule4:23-2(b)(3) permits a court to enter an order striking out pleadings or parts thereof . (1947) Art. New Jersey Court Rule 1:6 governs the procedure for filing motions in the Superior Court of New Jersey Law Division, and Chancery Division, General Equity. Below is a sample motion to compel discovery. John Lee argued the cause for respondents (Campbell, Foley, Lee, Murphy & Cernigliaro, attorneys; Stephen J. Foley, Jr., on the brief). Plaintiffs' Motion To Compel Production The Order shall set forth the self Registration is required, but its free ;]qIt% rL(PjV G)-r.=Pe$2 q&Fxj43 ]T~Pzxr@[yr3,(DJNg5j;xWVJmveeeUMY|jiZh(lg4 @kRh6t=?~/CYbF\ZgMK|xY.~%:TXA:zNZl :Wh+j)_H\`G"aJ?$4lLHKA1fO+jnwcrDOx/\ This is the most common discovery motion we file. See Comeford v. Flagship Furniture Clearance Center, 198 N.J. Super. NEW JERSEY N.J.R. The opinion of the court was delivered by HAVEY, J.A.D. den. Your subscription has successfully been upgraded. 3. stream To view this free sample motion to compel discovery, click the link below. Failure to Make Discovery; Sanctions. In lieu of any order or in addition thereto the court shall require the party failing to act to pay the reasonable expenses, including attorney's fees, caused by the failure, unless the court finds that the failure was substantially justified or that other circumstances make an award of expenses unjust. 8000 Sagemore Drive The form of order must indicate whether the motion was opposed or unopposed. For full print and download access, please subscribe at https://www.trellis.law/. Phone: 609-895-6990 ), certif. Thus, if discovery rules are to have any meaningful *19 effect upon calendar control and early disposition of litigation, they must be adhered to unless, for good cause shown, they are relaxed under R. 1:1-2. : 07-CV-02768 ORDER AND NOW this _____ day of _____, 2007, upon consideration of plaintiff=s Motion to Compel Full And Complete Interrogatory Responses and Documents, and the defendants= response thereto, IT IS HEREBY ORDERED that plaintiff=s motion is GRANTED, and within five (5) days from Rule 4:23-1. 2 0 obj N.J.R. http://www.judiciary.state.nj.us/calendars/motion_1.htm. 39, 46 (App.Div. The motion judge denied the motion in accordance with a "local rule"[1] controlling discovery motions which provided as follows: The parties then scheduled plaintiff's deposition for May 14, 1987. Union County Courthouse If the motion is denied, the court shall, after opportunity for hearing, require the moving party to pay to the party opposing the motion the reasonable expenses incurred in opposing the motion, including attorney's fees, unless the court finds that the making of the motion was substantially justified or that other circumstances make an award of expenses unjust. GQxE9P8bqo(b ND J`g;% SAMPLE MOTION TO COMPEL - Jeff Downey The last case I referred to them settled for $1.2 million. N.J.R. A-4788-11T4, at *9 (App. 329, 332 (App.Div. <> 424, 441.) WebWhere to Make the Motion Counsel must make a motion under FRCP 37 to compel a non-party's compliance with a subpoena in the compliancecourt (the court for the district where the discovery is or will be taken) (FRCP 37(a)(2)). 549, 553. Elizabeth, NJ 07207 ), The Supreme Court has held that it is especially inappropriate to grant summary judgment when discovery is incomplete[,] in particular, [w]hen 'critical facts are peculiarly within the moving party's knowledge. (See Velantzas v. Colgate-Palmolive Co.,(1988) 109N.J.189, 193; N.J. Anesthesia Assocs. N.J.R. Cumberland/Gloucester/Salem Superior Courts, Somerset/Hunterdon/Warren Superior Courts. Last. Superior Court of New Jersey Bergen County. endstream endobj 639 0 obj<>>> endobj 641 0 obj<>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI]>>/Group<>/StructParents 0/Tabs/S>> endobj 642 0 obj<> endobj 643 0 obj<> endobj 644 0 obj[250 0 0 0 0 0 0 0 333 333 0 0 250 333 250 0 500 500 500 500 500 0 500 0 500 0 333 0 0 0 0 0 0 722 667 722 722 667 611 778 778 389 500 778 667 944 722 778 611 0 722 556 667 722 722 1000 0 722 0 0 0 0 0 500 0 500 556 444 556 444 333 500 556 278 333 556 278 833 556 500 556 556 444 389 333 556 500 722 0 500] endobj 645 0 obj<>stream Clerk, Law Division See terms of use for more details. with or without prejudice,or rendering a judgment by default against the disobedient party who fails to obey an order to provide or permit discovery. N.J.R. Get free summaries of new New Jersey Superior Court, Appellate Division - Published Opinions opinions delivered to your inbox! Sample Motion to Compel Discovery | Maryland Personal Injury 7 dated July 1, 2015, each plaintiff shall serve his or her completed Plaintiff Fact Sheet on Briefs must be filed at the same time as the moving, opposing, or reply papers. Motion Day Courts hear motions 42, 51. An application for an order to a party may be made Every motion must be accompanied by a proposed order as prescribed by Rule 4:42-1(e) that, if granted, would provide the relief sought by the motion. LR-Civ. Feb. 25, 2022). Plaintiff just wants answers so we can proceed with the litigation without delay. ), Any party may serve on any other party a request (1) to produce and permit the party making the request, or someone acting on behalf of that party, to inspect and copy any designated documents (including writings, drawings, graphs, charts, photographs, phono-records, and other date compilations from which information can be obtained and translated, if necessary, by the respondent through electronic devices into reasonably usable form), or to inspect and copy, test, or sample any tangible things which constitute or contain matters within the scope ofR.4:10-2 and which are in the possession, custody or control of the party upon whom the request is served; (See Lindenmuth v. Holden (1996) 296 N.J. Super. We are an independent branch of government constitutionally entrusted with the fair and just resolution of disputes in order to preserve the rule of law and to protect the rights and liberties guaranteed by the Constitution and laws of the United States and this State. WebMotion to Compel Depositions in New Jersey What Is a Motion to Compel Depositions? There is a balancing act with these motions. 104 N.J. 386 (1986); State v. Whitehead, 159 N.J. Super. WebThe Court may impose sanctions in accordance with Rule of Civil Procedure 1.380(b) if discovery is not completed within 15 days from the date of entry of the order, and the proposed order should so provide. . The parties filed a consent motion to modify the scheduling order, and on June 11, 2018, the court granted the motion and extended the discovery deadline to August 10, 2018. Gregory R. Sellers FAX (856) 751-0868 This is the most common discovery motion we file. Plaintiffs, Civil No. Motions in the Law Division are considered according to a Motion Calendar adopted by the court on a yearly basis. 340 U.S. 877, 71 S. Ct. 123, 95 L. Ed. Zaccardi v. Becker, 88 N.J. 245, 252 (1982) (Zaccardi II). N.J.R. WebMotion to Compel Depositions I will fix the date, place and time for the deposition. Examples of motions include: Motion to dismiss the complaint Motion for x} xEWsff2`&9LN1 j G&U/]5hVw=QP(x ?]~;V}UUuuUL'!FD O=jCv7Qm+*sLX,X?jYovb,DL'Y7[w8(fq=+bJ?/ wvyMGvoj|W Kl'0Hkn9jhZ"P$Q YyyPQ+fUrnO5iEcer PYD~Y\Tm`[yt-tcbo%tYx 4 Discovery rules are designed to further "the public policies of expeditious handling of cases, avoiding stale evidence, and providing uniformity, predictability and security in the conduct of litigation." Div. Marlton, NJ 08053 Copyright 2018 All Rights Reserved by New Jersey Judiciary. Superior Court of New Jersey, Law Division. Plaintiffs Motion to Compel Discovery Responses from SALTZ MONGELUZZI & BENDESKY P.C. The entire team from the intake Samantha to the lawyer himself (Ron Miller) has been really approachable. action for wrongful-death damages was quickly followed by Bey Lea's motion to compel arbitration. hbbd```b``~ "[d5d/L~`b {``m0 X\ Y"?&zZ vr"d10128 _= ]7 Motion to Compel Discovery - New Jersey Essex Superior Court of VIA MAIL: This is mandated even when the responding party has not given any answers at all. WebA motion to compel discovery responses is filed when a party who has propounded discovery to either the opposing party or a third party believes that the discovery In most jurisdictions, the opposing party has 30 days to provide the requested information. Depositions of all the parties were scheduled for November 14, 1986 but were adjourned when defendant Elizabeth Rummel became ill. endstream endobj startxref See Zaccardi v. Becker, 162 N.J. Super. The Plaintiff, Mandy Glenn, by her attorney, Ronald V. Miller, Jr., moves pursuant to Maryland Rule of Procedure 2-432 for an Order compelling the Defendants, Steven Kennedy, Michael Davis, and Erie Insurance Exchange, to promptly produce all outstanding discovery, and in support, states as follows: WHEREFORE, the Plaintiff moves for an Order compelling the Defendants to produce complete and executed Answers to Interrogatories and the required documents within the next 15 days. 4:23-5(c)(amended eff 9/1/14). Prejudice has not even been asserted by defendant. v. Blackburn, No. xuRj %Q!I)~ The state judiciary website provides a guide to all citation forms used in New Jersey. 5 den. For the purposes of this subdivision an evasive or incomplete answer is to be treated as a failure to answer. You're all set! (P@SNl~.T@#iB@_hcBq EMqdD*~ i`|_Id2nN"^S8`#dJ`3g#9, 1983), certif. 4904 regarding unsworn falsifications to authorities. In practice, if exhibits attached to one paper are referenced in a subsequent paper, the exhibit is attached to the subsequent paper for convenience. 514, 517 (App.Div. WebNew Jersey Rules of Court New Jersey Rules of Court. trailer Further, plaintiff was ready and able at all times to attend the deposition. Cannot open/save sample. Electronically Stored Information. ), Courts have held that rules of discovery are to be liberally construed and accorded the broadest possible latitude. (SeeBlumberg v. Dornbusch, 139 N.J. Super. 4:27-1. xV]k@|?>uw`Jj-SK~BW0=,moVyxApt5y[x_YGm[#l~} ), The sanction of dismissal should be used sparingly, in only those cases where the order for discovery goes to the very foundation of the cause of action, or where the refusal to comply is deliberate and contumacious. (See Corp. Realty Servs., LLC v. Croghan, No. 638 17 (856) 751-8383 If the motion is granted, the court shall, after opportunity for hearing, require the party or deponent whose conduct necessitated the motion to pay to the moving party the reasonable expenses incurred in obtaining the order, including attorney's fees, unless the court finds that the opposition to the motion was substantially justified or that other circumstances make an award of expenses unjust. %%EOF She also argues that the motion judge abused her discretion in dismissing the complaint without making a finding of bad faith or considering alternative sanctions. . JEDS EF-953478, ORDER TO COMPEL DISCOVERY-Granted by Judge FRIEDMAN, SANDER, D re: MOTION , ORDER TO COMPEL DISCOVERY-Granted by Judge CHELL, TIMOTHY, W re: MOTION TO, Ryan Michael Vs Mj Builders & Devel Group Llc, Motion to Compel Further Responses to Interrogatories, Motion for SanctionsFailure to Comply with Discovery, [DOCUMENT] Cit Finance Llc Vs 17240 Hall, Llc. Respectfully submitted,Miller & Zois, LLC, Ronald V. Miller, Jr.1 South St, #2450Baltimore, MD 21202(410)779-4600(410)760-8922 (Fax)Attorney for the Plaintiff. Div. The case settled and I got a lot more money than I expected. den. Your recipients will receive an email with this envelope shortly and