Noreturn Posted March 5, 2020 Report Share Posted March 5, 2020 Does anyone have a sample Motion for Sanctions they'd like to share? Preferably dealing with failure to disclose, supplement an earlier response but any discovery topic will help. My situation: Parties participated in discovery, specifically asked plaintiff to disclose any / all potential witnesses Plaintiff answer " Plaintiff's only witness...custodian of records, discovery is ongoing plaintiff will supplement answer in accordance with the Courts Scheduling Order" --Plaintiff never supplemented-- Court Scheduling order: Parties must exchange and file with the court a list of witnesses they may call to testify. Include witness name, phone number, address and a brief description of expected testimony Due 10 days prior to trial--- Plaintiff JDB = Did not file or serve list--two live witnesses testified both undisclosed. Quote Link to comment Share on other sites More sharing options...
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