IN
THE CIRCUIT COURT FOR
ANNE
ARUNDEL COUNTY, MARYLAND
MICHAEL G, LENETT
Plaintiff,
v.
VIRGINIA
R.
RAMSEY,
ET AL.
Defendants.
Case
No.:
02C11163878
PLAINTIFF'S
MOTION
TO
STRIKE
COMES
NOW,
the
Plaintiff, Michael
G. Lenett, by
undersigned
counsel,
and
moves
thisHonorable Court to strike Defendant Ramsey's Answer and approximately 200 pages of exhibitsanddiscovery that Defendant Ramsey improperly appendedto herAnswer,and forcause states
as
follows:
1.
OnSeptember6,
2011,
Plaintiff
filed acomplaint against Defendant Ramseyandothers,asserting claims
for
defamation
and
false
light
arising
from,
among other things, defamatorystatements that Defendant Ramsey published that personally attacked
Plaintiff.
2. On
October 24,2011,
Defendant Ramsey
filed an
Answer
to the
complaint. With
her
Answer, Defendant Ramsey filed approximately 200 pages of documents, which includedunsigned answers to interrogatories and other documents. Ms. Ramsey's Answer references and
relies
on
these documents.
3. The
Maryland Rules
do not
permit Defendant Ramsey
to file
these documents with
her
Answer. First, with respectto thediscovery,Md.Rule
2-401
(d)(2)
provides that "discovery
material
shall not be filed with the court." (Emphasis added). Here, Defendant Ramsey clearlycontravened this Rule when
she filed
unsigned interrogatory
responses.
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Former Senator Mike Lenett's Motion to Strike Ginger Ramsey's Response
IN THE CIRCUIT COURT FOR ANNE ARUNDEL COUNTY, MARYLAND MICHAEL G, LENETT Plaintiff,
v.
VIRGINIA R. RAMSEY, ET AL. Defendants.
Case No.: 02C11163878
PLAINTIFF'S MOTION TO STRIKE COMES NOW, the Plaintiff, Michael G. Lenett, by undersigned… (More)
v.
VIRGINIA R. RAMSEY, ET AL. Defendants.
Case No.: 02C11163878
PLAINTIFF'S MOTION TO STRIKE COMES NOW, the Plaintiff, Michael G. Lenett, by undersigned… (More)
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