Missouri civil procedure Discovery

[mrmrsg]

I have read of the local court rules circut court 42 and the Missouri rules of civil proceudre and am at a loss.

I am preparing to file my answer with the court, I have also prepared the first set of admissions and request for the production of documents to send to the Plantiff

Can I just send the admissions and the request to the plantiff or do I have to file a motion with the court before sending these last two items?

If i have to file a Motion for Production of Documents and first request for admissions what should the motion contain?

Thanks

[daybyday]

Thus far my experience in Missouri Civil Court would lead me to reccommend that you;

1) file Affidavit of Denial (answer to summons)

2) Motion for Prouction of Documents

3) Request for Admissions

4) Certificate of Service

Make 4 copies of number 3 and three copies of 1 and 2. File 1, 2 and 3 with the court clerks office having them stamp them. The clerk will keep one copy of each and keep them with the file. Put in envelope and mail to Plaintiff attorney address listed on summons, one copy of 1 and 2, two copies of 3. Mail via Certified return. Keep a copy for your file

When certified return card is received, make three copies and mark Defendents Exibit "A". Again take to court clerks office, along with #4, have them stamped and mail copy of certified return card and #4 to Plaintiff attorney address. Keep one for your file and the clerk will keep a copy for the courts file.

On request for admissions be sure to put at the end: "A FAILURE TO TIMELY RESPOND TO REQUESTS FOR ADMISSIONS IN COMPLIANCE WITH RULE 59.01 SHALL RESULT IN EACH MATTER BEING ADMITTED BY YOU AND NOT SUBJECT TO FURTHER DISPUTE."

Hope this helps!

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[mrmrsg]

How should the motion be worded?