Example Motion to Compel

 County Court District Court
_____Larimer_________ County, Colorado
Court Address:201 LaPorte Ave.
Fort Collins, CO 80521


Scott Walker,

Plaintiff.

v.

Tanya Brewster,

Defendant.









COURT USE ONLY
Jessica Thompson, Attorney at Law
2345 Litigator Way
Fort Collins, CO 80525
Phone Number: (970)493-5555
FAX Number: (970)555-5555
E-mail: LLawyer@legal.com
Atty. Reg. #: 11111 Case Number:




Division Courtroom
MOTION TO COMPEL


The plaintiff appears by and through his attorney, Jessica Thompson, and respectively submits this Motion to Compel against the defendant, Tanya Brewster.
For the following reasons:
1. Upon being served on July 17, 2008 thirty days has passed which is required by Colorado Rules of Civil Procedure Rule 33(b)(3), the defendant has still not answered our interrogatory nor has the defendant and their attorneys communicated with their intention to do so.
2. The attorney, Jessica Thompson, for the plaintiff, Scott Walker, has with due diligence and good faith attempted to contact the attorney for the Defendant in every way in order to seek the answer to the interrogatory.

Wherefore Plaintiff hereby requests the court to compel discovery of the interrogatory asked of the defendant, Tanya Brewster, by means of a judge’s order.



Verification

State of Colorado )
) ss.
County of Larimer )

The undersigned Plaintiff, having been first duly sworn upon his oath, deposes and states that he is the Plaintiff in the above-referenced action, that he has reviewed the foregoing Motion to Compel, and that the statements made therein are true and correct to the best of his knowledge, information, and belief.

_______________________
Scott Walker, Plaintiff

Subscribed and sworn to me before this _____day of _____20___, by .
Witness my hand and official seal. My commission expires:


______________________
Notary Public
Address: 1609 Oakridge Drive
Fort Collins, Co 80525


Dated: _August 17, 2008







CERTIFICATE OF SERVICE

I certify that on ________________________(date) the original of this Motion was filed with the Court; and a true and accurate copy of this MOTION TO COMPEL was served on the other party by placing it in the United States mail, postage pre-paid and addressed to the following: ______________________________________
______________________________________
______________________________________

______________________________________
 Plaintiff OR  Defendant



 County Court District Court
_____Larimer_________ County, Colorado
Court Address:201 LaPorte Ave.
Fort Collins, CO 80521


Scott Walker,

Plaintiff.

v.

Tanya Brewster,

Defendant.









COURT USE ONLY
Jessica Thompson, Attorney at Law
2345 Litigator Way
Fort Collins, CO 80525
Phone Number: (970)493-5555
FAX Number: (970)555-5555
E-mail: LLawyer@legal.com
Atty. Reg. #: 11111 Case Number:




Division Courtroom
ORDER GRANTING PLAINTIFF’S MOTION TO COMPEL

This matter came before the court for review of the Plaintiff’s motion to compel discovery on August 17, 2008. The court reviewed the file and the motion and having been duly advised in the premises, hereby grants the same. Counsel for the Plaintiff will notice the matter in for setting of due-date when the defendant must comply with the plaintiff’s motion within one week of the courts entering of judgment.

BY THE COURT:

________________
Judge