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Discovery/Rogs not answered ? What next?


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Received Summons from Amex (local attorney) a few months back. I answered...they sent Discovery which I answered. They have not answered my Discovery/Rogs/Production of Documents at all.

My question is what to do next.

Should I send a reminder letter to them (do I copy court)

Do I go straight to filing a motion for them to answer Discovery

Dismissal ?

Just want to make the right next move. Thanks

The original complaint included the following with nothing else attached.

1.Defendant enetered into agreement...etc

2. Defendant usd card to make purchases

3. Defendant failed to make payment

4. plaintiff demands judgement...etc

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Rule 26 subpart as shown:

(g) Discovery Motions

(1) Motions. No written motions under Rule 26 through 37 shall be

filed without the prior approval of a justice or judge of the court in which the

action is pending. The moving party shall first confer with the opposing party in a

good faith effort to resolve by agreement the issues in dispute. If the dispute is not

resolved by agreement, the moving party shall request a hearing from the clerk by

letter. The letter shall succinctly and without argument or citation describe the

nature of the dispute and the relief requested. In cases involving objections to

interrogatories or document requests, the moving party shall attach to the letter

copies of only the specific objections in question and the specific interrogatories or

requests to which objection has been made. In exigent circumstances a request for

a hearing may be made to the clerk by telephone or in person. The request for a

hearing constitutes a representation to the court, subject to Rule 11, that the

conference with the opposing party has taken place and that the moving party has

made a good faith effort to resolve the dispute. The clerk shall inform the moving

party of the manner, date and time of the hearing. The moving party shall provide

prompt notice of the hearing to all the other parties. If the hearing is to be

conducted by telephone conference or video conference, the moving party shall

connect all other parties who elect to participate and shall initiate the telephone or

video conference call to the court.

(2) Hearing or Conference. The court may issue an order without a

hearing if the request is based on a failure to either answer or object to outstanding discovery requests. In all other cases the parties shall be prepared to offer oral argument at a hearing or a telephone or video conference on the discovery issues in question if scheduled by the court. No written argument shall be submitted and no motion papers shall be filed with the clerk without prior leave of the court.

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Rule 26 subpart as shown:

(g) Discovery Motions

(1) Motions. No written motions under Rule 26 through 37 shall be

filed without the prior approval of a justice or judge of the court in which the

action is pending. The moving party shall first confer with the opposing party in a

good faith effort to resolve by agreement the issues in dispute. If the dispute is not

resolved by agreement, the moving party shall request a hearing from the clerk by

letter. The letter shall succinctly and without argument or citation describe the

nature of the dispute and the relief requested. In cases involving objections to

interrogatories or document requests, the moving party shall attach to the letter

copies of only the specific objections in question and the specific interrogatories or

requests to which objection has been made. In exigent circumstances a request for

a hearing may be made to the clerk by telephone or in person. The request for a

hearing constitutes a representation to the court, subject to Rule 11, that the

conference with the opposing party has taken place and that the moving party has

made a good faith effort to resolve the dispute. The clerk shall inform the moving

party of the manner, date and time of the hearing. The moving party shall provide

prompt notice of the hearing to all the other parties. If the hearing is to be

conducted by telephone conference or video conference, the moving party shall

connect all other parties who elect to participate and shall initiate the telephone or

video conference call to the court.

(2) Hearing or Conference. The court may issue an order without a

hearing if the request is based on a failure to either answer or object to outstanding discovery requests. In all other cases the parties shall be prepared to offer oral argument at a hearing or a telephone or video conference on the discovery issues in question if scheduled by the court. No written argument shall be submitted and no motion papers shall be filed with the clerk without prior leave of the court.

Thanks....so it looks like I should start with the letter to the attorney. How long should I give them to respond before sending letter to to the clerk requesting hearing. Thanks again.

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Thanks....so it looks like I should start with the letter to the attorney. How long should I give them to respond before sending letter to to the clerk requesting hearing. Thanks again.

Also...is there any format for sending a letter to attorney requesting answers....and it looks like I wouldnt need to copy court on that letter just yet? Thanks

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Normally you should give them 10 days, and make sure you put that in the letter. No copy to the court. Make sure you send it certified mail.

ok...thanks. Does the letter have to be in any special format, or do I simply state that my rogs wre not answered please answer within 10 days?

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ok...thanks. Does the letter have to be in any special format, or do I simply state that my rogs wre not answered please answer within 10 days?

The rule doesn't state any particular format. I think just a letter reminding them that you sent your requests on _________(date), but have not yet received their responses would be appropriate.

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  • 3 weeks later...

So I sent a letter with deadline to receive Discovery back which of course I did not get back. Given the Maine law below, what would my next step be. There is nothing scheduled coming up on case...pre trial hearing would be next. Should I send letter to court as described below? Thanks

1) Motions. No written motions under Rule 26 through 37 shall be

filed without the prior approval of a justice or judge of the court in which the

action is pending. The moving party shall first confer with the opposing party in a

good faith effort to resolve by agreement the issues in dispute. If the dispute is not

resolved by agreement, the moving party shall request a hearing from the clerk by

letter. The letter shall succinctly and without argument or citation describe the

nature of the dispute and the relief requested. In cases involving objections to

interrogatories or document requests, the moving party shall attach to the letter

copies of only the specific objections in question and the specific interrogatories or

requests to which objection has been made. In exigent circumstances a request for

a hearing may be made to the clerk by telephone or in person. The request for a

hearing constitutes a representation to the court, subject to Rule 11, that the

conference with the opposing party has taken place and that the moving party has

made a good faith effort to resolve the dispute. The clerk shall inform the moving

party of the manner, date and time of the hearing. The moving party shall provide

prompt notice of the hearing to all the other parties. If the hearing is to be

conducted by telephone conference or video conference, the moving party shall

connect all other parties who elect to participate and shall initiate the telephone or

video conference call to the court.

(2) Hearing or Conference. The court may issue an order without a

hearing if the request is based on a failure to either answer or object to outstanding discovery requests. In all other cases the parties shall be prepared to offer oral argument at a hearing or a telephone or video conference on the discovery issues in question if scheduled by the court. No written argument shall be submitted and no motion papers shall be filed with the clerk without prior leave of the court.

03-06-2012 12:46 PM

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