SUPERIOR COURT OF THE DISTRICT OF COLUMBIA

FAMILY COURT – DOMESTIC RELATIONS BRANCH

NAME. *
*
Plaintiff, *
*
v. * CASE NO.: _______________
* JUDGE
NAME, * Next Court Date:
*
Defendant. *
*
* * * * * * * * * * *

MOTION TO COMPEL DISCOVERY,

AND FOR SANCTIONS AND ATTORNEY’S FEES

COMES NOW the PLAINTIFF, NAME., by and through his Counsel of Record,

Angela D. Minor, Esq., and the Law Offices of MINOR & WILLCOX, LLC and moves this

Honorable Court to Compel the DEFENDANT, NAME to answer and produce documents

responsive to Discovery requests in support thereof, states the following:

1. That the parties are before this Honorable Court on the matter of Child Custody,

Visitation and Child Support.

2. That on DATE, the parties were before the Court for a Status Hearing and as a

result of the parties’ Discovery was at issue and therefore it was extended by this Honorable

Court for two weeks for the Defendant, NAME, to provide Discovery responses to Plaintiff’s

Counsel no later than, DATE.

3. That DATE, has past and it is September 6, and Counsel for the Plaintiff has not

received responses, production or a request for an extension from Defendant’s Counsel.

4. That Discovery in the form of Interrogatories and Request for Production of

Documents were served in this case on the Plaintiff on or about DATE, via first-class mail, to:
COUNSEL., ADDRESS, Counsel of Record for the Defendant.

5. That the Defendant’s Certificate of Discovery was promptly filed with the Court.

6. That to date the Defendant has not filed responses to Plaintiff’s Interrogatories

and Requests for Production of Documents after agreeing to do so in open court and after an

extension was requested and granted.

7. That the Plaintiff wants the Court to know that the Plaintiff and his Counsel

responded in a timely manner to Defendant’s Discovery requests.

8. That furthermore, the parties will likely go to trial on the matter as the Plaintiff’s

Counsel sent a Settlement Letter to Defendant’s Counsel and has not received a response on that

correspondence as well.

9. That to date Plaintiff’s Counsel is left with no recourse but to seek this court’s

intervention to Compel Discovery responses as Counsel for the Defendant has failed to provide

any discovery on this matter.

10. That as a matter of law the Plaintiff is requesting that the Defendant be barred

from entering certain evidence at the merits trial.

11. That the Plaintiff has incurred Attorney’s Fees over this matter in the amount of

$950.00 and that Plaintiff’s Counsel has moved in good faith effort to work with Defendant’s

Counsel in order to obtain discovery requests and as such the Defendant through his Counsel of

Record is seeking Attorney’s Fees from the Defendant and Defendant’s Counsel for failing to

comply.
WHEREFORE, the Plaintiff prays that this Honorable Court grant the following:

A. Grant Plaintiff’s Motion to Compel Discovery and for Sanctions and Attorney’s

Fees;

B. That the Court order immediate sanctions for failure to provide discovery and bar the

Plaintiff from entering certain evidence at trial;

C. That the Court order that the Discovery responses be delivered no later than one week

from the ruling of this Court’s Motion to Compel;

D. Grant the Plaintiff’s reasonable attorney’s fees associated with this Discovery

requests upon the Defendant; and

E. And for such other and further relief as the nature of Defendant’s cause may require.

Point and Authorities

1. D.C. Rule 12 and 16(b).

2. The record herein.

Respectfully submitted,
By: MINOR & WILLCOX, LLC

______________________
Angela D. Minor, Esq., Bar #
Attorney and Counselor at Law

aminor@minorwillcoxlaw.com

Counsel for Plaintiff

 CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this th day of ______________, 2016, a copy of the

foregoing Motion to Compel Discovery and for Sanctions and Attorney’s Fees and
Order was mailed, via first class to:

ADDRESS
ADDRESS

Counsel for Defendant.

_____________________
Angela D. Minor, Esq., Bar #
 SUPERIOR COURT OF THE DISTRICT OF COLUMBIA
FAMILY COURT – DOMESTIC RELATIONS BRANCH

NAME. *
*
Plaintiff, *
*
v. * CASE NO.: _______________
* JUDGE
NAME, * Next Court Date:
*
Defendant. *
*
* * * * * * * * * * *
ORDER

UPON CONSIDERATION for the Defendant’s Motion to Compel filed herein,

the contents having been read and considered by the Superior Court of the District

of Columbia and for failure to respond to discovery requests, failure to comply

with discovery pursuant to District of Columbia Rules, it is therefore upon this_____ day of

______________, 2016.

ORDERED, that the Plaintiff’s Motion be and HEREBY is GRANTED;

and it is further,

ORDERED, that the Plaintiff must pay reasonable attorney’s fees associated

with this Discovery request in the amount of $__________; and it is further,

ORDERED, that the Defendant shall provide Discovery no later than:

________________________________________________________________ .

_____________________________
JUDGE