Assume that your firm, Stahl & Beetum, PC ,
13 Sol St., Wigmore, IL 00001, served the interrogatories and Notice to
Produce on Plaintiff’s attorney. The Wigmore Supreme Court Rule 213 Written Interrogatories
to Parties subsection (d) requires the opposing party to answer the
interrogatories within 28 days of receipt. The Wigmore Supreme Court
Rule 214 Discovery of Documents subsection (a) requires that
the opposing party tender the requested documents within 28 days of
receipt of the Notice to Produce. The Wigmore Supreme Court Rules are
Your supervising attorney, B. G. Brothers tells you that she served
Interrogatories and a Notice to Produce on Plaintiff’s counsel over 120
days ago. She further tells you that she has had two personal
conferences with Plaintiff’s counsel, Rich N. Moore, requesting that he
immediately provide his client’s responses to both discovery requests.
In both conferences Mr. Moore promised to serve his client’s responses
to both discovery requests within two weeks, but he has not done so.
Brothers tells you she is tired of waiting and getting empty promises
from Plaintiff’s counsel. She asks you to draft a Motion to Compel
Plaintiff’s Answers to Written Discovery. She tells you to review the
applicable Wigmore Supreme Court Rules on discovery and then hands you a
document with the applicable rules. It is attached here.
Ms. Brothers tells you to read and include in your motion citation to
and a discussion of case law. She says you may use Transamerica Ins.
Group v. Lee, 164 Ill. App. 3d 945, 518 N.E.2d 413 (1987), Mueller v.
Insurance Ben. Admrs., Inc., 175 Ill. App. 3d 587, 529 N.E.2d 1126
(1988), or such other case you may believe appropriate. She says the
Motion is due by Sunday at 1159pm. She also gives you a form for a Motion to Compel that she has from her prior firm which was a Plaintiff’s firm.