Being sued by Citibank- my ROG's were objected to overall (Boilerplate BS). Here is my motion to compel....
1. The present action was commenced on (date) by service of a Summons and Complaint upon (Defendant).
is this the original date of my ROG's or the date I am requesting Motion to Compel ?
Do I need to have the motion served or do I just mail it CMRR like the plaintiff does ?
2. An Answer was duly served on Plaintiff on (date), a date within the required time for service.
Same question- today's date or date of initial ROG request ?
3. Rule 1.280 permits Discovery as a method of narrowing the issues for the Court to decide.
4. Plaintiff was served with a Demand for Discovery, Production of Documents and Admissions on (date)
5. Rule 1.340(a) prescribes the required time period under which Discovery must be responded to.
6. The time period for response to Defendant's Demand for Discovery, Production of Documents and Admissions has passed with no response from Plaintiff.
NOW THEREFORE
7. Defendant prays the Court Order Plaintiff to respond to Defendant's Demand for Discovery, Production of Documents and Admissions on or before (45 days)
Do I include arguments for why my ROG's should be answered ? Do I include an "order" for the judge to sign ? How do I Word the order ?
