Coronavirus Update: To New & Existing Clients Learn More ›

Super Lawyers
Illinois State Bar Association
Justia Lawyer Rating
Million Dollar Advocates Forum
Avvo Rating
BBB Accredited Business

Motion 13 - product liability plaintiffs motion to compel defendants response to discovery request

Download PDF Version

Plaintiff's Motion to Compel

Plaintiffs, SUZANNE COLANGELO and CARMEN COLANGELO, by and through their attorneys, PAVALON & GIFFORD, move this honorable court for an order compelling the defendants, MICHAEL J. SCHIED, M.D., DANA S. ZIEBEL, M.D. and LaGRANGE WOMEN'S CLINIC, S.C., to respond to all outstanding written discovery within fourteen (14) days, and in support thereof states:

1. On June 5, 1995, plaintiffs served upon defendants certain written interrogatories and a production request. (SeeExhibit A, Written Discovery, attached hereto.)

2. On June 18, 1996, counsel for plaintiffs called counsel for the defendants and had a 201(k) telephone conference regarding defendants' answers to written discovery. At that time, counsel for the defendants said he would verbally provide answers to the various interrogatories at the deposition of defendant, Dr. Schied, which was set for the following day, and would provide written, signed answers to interrogatories shortly thereafter. In the interest of allowing the defendant's deposition to proceed, plaintiff's counsel agreed to the above-mentioned plan regarding the outstanding written discovery.

3. On October 3, 1996, counsel for plaintiffs sent a letter to counsel for defendants requesting that defendants make a written response to plaintiffs' written discovery within 14 days. (See Exhibit B, correspondence dated October 3, 1996, attached hereto.)

4. To date, plaintiffs have not received the defendants' answers to their written discovery, and will be prejudiced if same are not provided within 14 days.

WHEREFORE, plaintiffs, SUZANNE COLANGELO and CARMEN COLANGELO, pray that this court grant their motion and enter an order compelling the defendants to respond to all outstanding discovery within fourteen (14) days.

Look at our product liability page for more information.
250M + Recovered for Our Clients
No Fee Guarantee We Never Charge a Fee Unless We Win
Available 24/7 Available 24-Hours per Day When You Need Us
Client Reviews
Jonathan Rosenfeld was professionally objective, timely, and knowledgeable. Also, his advice was extremely effective regarding my case. In addition, Jonathan was understanding and patient pertaining to any of my questions or concerns. I was very happy with the end result and I highly recommend Jonathan Rosenfeld. Michonne Proulx
Extremely impressed with this law firm. They took control of a bad motorcycle crash that left my uncle seriously injured. Without any guarantee of a financial recovery, they went out and hired accident investigators and engineers to help prove how the accident happened. I am grateful that they worked on a contingency fee basis as there was no way we could have paid for these services on our own. Ethan Armstrong
This lawyer really helped me get compensation for my motorcycle accident case. I know there is no way that I could have gotten anywhere near the amount that Mr. Rosenfeld was able to get to settle my case. Thank you. Daniel Kaim
Jonathan helped my family heal and get compensation after our child was suffered a life threatening injury at daycare. He was sympathetic and in constant contact with us letting us know all he knew every step of the way. We were so blessed to find Jonathan! Giulia
Jonathan did a great job helping my family navigate through a lengthy lawsuit involving my grandmother's death in a nursing home. Through every step of the case, Jonathan kept my family informed of the progression of the case. Although our case eventually settled at a mediation, I really was impressed at how well prepared Jonathan was to take the case to trial. Lisa