§ 11:16 Plaintiff's motion to compel production

COMMONWEALTH OF MASSACHUSETTS

_____ , ss. SUPERIOR COURT

CIVIL ACTION NO. _____ CIVIL ACTION NO. _____

________
)
________ )
PLAINTIFF(S) )
)
v. )
)
)
________ )
DEFENDANT(S) )
________ )

PLAINTIFF'S MOTION TO COMPEL PRODUCTION

Pursuant to Mass.R.Civ.P. 37(d)

Now comes the Plaintiff and, pursuant to Mass.R.Civ.P. 37(d), moves to compel Defendant
_____ to produce within thirty days the documents described in Plaintiff's Request For
Production.

As grounds for this motion Plaintiff states as follows:

1. Defendant has failed to respond to Plaintiff's Request For Production within thirty
days after service of Plaintiff's Request For Production (at least forty-five days after service
of the complaint).

2. On _____ , _____ , Plaintiff served Plaintiff's Request For Production. A copy of

Plaintiff's Request For Production is attached hereto as Exhibit A.

3. To date Defendant has failed to serve any response to Plaintiff's Request For
Production.

WHEREFORE, Plaintiff respectfully requests that this Court order Defendant to produce
within thirty days the documents described in Plaintiff's Request For Production.

By Plaintiff's attorney,

______________________
Attorney for Plaintiff

BBO #_______________

Address

Telephone Number

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[CERTIFICATE OF SERVICE]