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2009-08-18 response to motion to compel

2009-08-18 response to motion to compel

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Published by Sam Hasler

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Published by: Sam Hasler on Aug 19, 2009
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05/11/2014

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nINSERT "fam-1 caption.wpt" o
RESPONSE TO MOTION TO COMPEL
nClient's party designationo responds to nOpposing party's party designationo's Motion to Compel as follows:
1. ThenOpposing party's party designation o fails to comply with Indiana Trial Rule 26(F) which requires the
following before the filing of any Motion to Compel:

Before any party files any motion or request to compel discovery pursuant to Rule 37, or any motion for protection from discovery pursuant to Rule 26(C), or any other discovery motion which seeks to enforce, modify, or limit discovery, that party shall:

(1) Make a reasonable effort to reach agreement with the opposing party concerning the matter which
is the subject of the motion or request; and
(2)

Include in the motion or request a statement showing that the attorney making the motion or request has made a reasonable effort to reach agreement with the opposing a ttorney(s) concerning the matter(s) set forth in the motion or request. This statement shall recite, in addition, the date, time and place of this effort to reach agreement, whether in person or by phone, and the names of all parties and attorneys participating therein. If an attorney for any party advises the court in writing that an opposing attorney has refused or delayed meeting and discussing the issues covered in this subsection (F), the court may take such action as is appropriate.

WHEREFORE,nClient's party designation o requests that the court deny thenOpposing party's party
designationo's Motion to Compel.

___________________________________________
Samuel C. Hasler, 11971-48
Attorney for Respondent
1010 W. 8th St. Suite 5
Anderson, IN 46016
765-64 1 -7906
Fax: 765-374-3811
Computer Address: samuelhasler\u00a9yahoo .com

nINSERT "Signature and certificate of service.wpt" o

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