[redacted]

COMES NOW Plaintiff in the above-matter and hereby moves the Court for an order compelling Defendant [redacted] to prepare and serve a response and provide the documents as requested in Plaintiff’s First Interrogatories and Plaintiff’s First Request for Production of Documents to Defendant. In support of this motion, the Plaintiff states to the Court as follows:

1. Plaintiff served its First Interrogatories and First Request for Production of Documents on Defendant on September 9, 2014 and responses to said discovery were due on October 24, 2014.
2. On Monday, October 27, 2014, Counsel for Plaintiff sent an email to Counsel for Defendant inquiring about the status of Defendant’s responses to the discovery. Counsel for Plaintiff further informed opposing counsel if full and complete responses were not provided or a request for additional time was not made by October 31^st, Counsel would file a motion to compel the discovery with the Court. Counsel’s email is attached hereto as Exhibit “1”.
3. To date, Counsel for Plaintiff has not received responses to the requested discovery nor has he received a response requesting additional time to respond.

WHEREFORE, the Plaintiff requests that the Court compel Defendant [redacted] to prepare and serve a response and provide the documents as requested in Plaintiff’s First Interrogatories and Plaintiff’s First Request for Production of Documents to Defendant and for such other and further relief as the Court deems just and equitable in the premises.