Motion to Compel

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					             IN THE DISTRICT COURT OF [INSERT COUNTY NAME] COUNTY
                               STATE OF OKLAHOMA

[INSERT PLAINTIFF'S NAME HERE],                        )
                                                       )
                   Plaintiff,                          )
                                                       )
v.                                                     )        Case No. [Insert Case No. Here]
                                                       )
[INSERT YOUR NAME HERE],                               )
                                                       )
                   Defendant.                          )

                                         MOTION TO COMPEL

       COMES NOW the Defendant and moves this Honorable Court to issue an order compelling the

Plaintiff to answer forthrightly Defendant's Request for Production of Documents. In support of this

motion, Defendant offers the Court the following:

           1. Defendant served its Request for Production of Documents to Plaintiff on or about

               [Provide the Date that your discovery was sent].

           2. Plaintiff returned its answers to Defendant's Request for Production of Documents to

               Defendant on or about [Provide the date that the debt collector sent its answers to your

               discovery]. A copy of Plaintiff's answers are attached as Exhibit A.

           3. Plaintiff's answers wholly failed to comply with Defendant's Request for Production of

               Documents, even failing to provide a copy of the original contract or application for

               credit that it alleges is in its possession.

           4. Defendant called Plaintiff's attorneys to inform it that its answers to Defendant's Request

               for Production of Documents were unsatisfactory and to ask it to comply with these

               Request for Production of Documents, particularly, to provide a copy of the original

               contract or written application for credit that it alleges in its possession.

           5. Furthermore, on [Provide the date that your letter was mailed], Defendant mailed its

               objections to Plaintiff regarding its failure to produce documents, but Plaintiff failed to
              respond to this letter. A copy of this letter is attached as Exhibit B.



       WHEREFORE, Defendant moves this Honorable Court to compel Plaintiff to produce

Defendant's Request for Production of Documents.



                                       NOTICE OF HEARING



       This Motion to Compel has been set for hearing on the _____ day of ______________, [Year].

Such hearing will occur at ________ pm/am in the courtroom of Judge _______________.


                                                             _____________________________
                                                             [Print Your Name Here & Sign Above]
                                                             [Address Line I]
                                                             [Address Line II]
                                                             [Your Phone Number]




                                   CERTIFICATE OF MAILING


       I hereby certify that a true and correct copy of the foregoing Motion to Compel was this _____

day of __________, [Year] mailed to the following attorney of record:

       [Plaintiff's Attorney's Name]
       [Address Line I]
       [Address Line II]


                                                             _____________________________
                                                             [Print Your Name Here & Sign Above]
                                                             [Address Line I]
                                                             [Address Line II]
                                                             [Your Phone Number]

				
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