For this assignment, you’ll be completing a Motion to Compel. Again, this is the sort of task you might actually do at a law firm.
Our law firm, Shaliro, LLC, is handling Carrie Madison’s Equal Employment Opportunity Commission case against her employer, the CIA, for wrongful termination. Our office previously filed discovery in this case and the secretary, Saul Beren, did not reply to our discovery request. The sequence of events is as follows:
- The discovery was time stamped and filed on October 12th. The CIA agency had until November 12th to respond.
- A time stamped copy was delivered via certified mail on October 13th to the Agency’s attorney, Brody Johnson. We received a signed green card showing receipt for the certified mail on October 21st by Mr. Johnson’s office.
- On November 23rd, we emailed Mr. Johnson inquiring to the Agency’s responses to discovery. On November 24th, Mr. Johnson emailed our office back stating that he had left two messages for Mr. Beren to reply to the discovery or else a motion to compel would be filed by our office.
- On December 18th, we sent a certified letter to Mr. Johnson stating that we would be filing a motion to compel if we did not receive responses by the end of the month. We received the signed proof of service signed by Mr. Johnson’s office for that letter on December 27th.
- On the following January 15th, Carrie’s attorney, who is your boss, (Robert Shaliro) spoke with Mr. Johnson over the phone. Mr. Johnson did not know why the agency has not responded to the discovery requests.
Mr. Shaliro would like you to file a motion to compel for sanctions against the CIA and Mr. Beren.
Using Microsoft Word, prepare the motion to compel based on the facts of the scenario.
- You can use the following site for a sample: http://www.sniderlaw.com/articles/motion-to-compel.pdf (Links to an external site.)
- The EEOC number is 333-23-2220 Agency #W-133-54333-34
Please complete the entire document and pay attention to the details. Your document should be consistent with the Legal Writing Guidelines and should be “Law Office Ready”.