Assume that you are Attorney Cheathem's paralegal and that the case has progressed to the point where discovery is in progress. Despite repeated good faith requests to Attorney Howe for certain items of discovery, he has refused to respond to such attempts and requests. As the paralegal working on behalf of the Plaintiff, you are to draft a legally sufficient motion to compel discovery due to this failure, all for Mr. Cheathem's signature.

INFORMATION

1. Trial Court - United States District Court for the Northern District of Florida, Tallahassee Division
2. Appeals Court - United States Court of Appeals for the 11th Circuit, Atlanta, GA
3. Civil Action No. 2023-0501TLH
4. Plaintiff is Jane Doe (Tallahassee, FL resident)
5. Defendant is Harry Roe (Thomasville, GA resident)
6. Type Case - Personal Injury - Auto Accident occurring in Tallahassee, FL with
negligence on the part of Mr. Roe in running a red light and striking Ms. Doe, causing her
serious bodily injury
7. Date of occurrence: 1/1/2022
8. Date of Jury Verdict in favor of Plaintiff: April 30, 2023
9. Attorney for Plaintiff - Dewey Cheathem, Esquire (FL Bar member)
10. Attorney for Defendant - Arthur N. Howe, Esquire (GA and FL Bar Member)

Answer rating: 100% (QA)

Your Name Paralegal to Attorney Dewey Cheathem Esquire Address City State Zip Phone Number Email Address Date Honorable Judges Full Name United States ... View the full answer