Free Motion to Compel - District Court of Federal Claims - federal

Case 1:05-cv-00981-MMS

Document 24

Filed 03/26/2007

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS K-CON BUILDING SYSTEMS, INC., ) ) Plaintiff, ) ) vs. ) ) UNITED STATES OF AMERICA, ) DEPARTMENT OF HOMELAND SECURITY, ) UNITED STATES COAST GUARD, ) ) Defendant. ) )

No.: 05-981 C (Judge Sweeney)

PLAINTIFF'S MOTION TO COMPEL Pursuant to RCFC 37, the Plaintiff, by and through the undersigned attorney, hereby moves before this Court for an Order compelling Defendant to produce documents in response to discovery requests, and an Order directing Defendant to pay Plaintiff's reasonable expenses incurred in filing this motion and obtaining this Order. This motion is based on Defendant's failutre to provide documents responsive to Plaintiff's First Set of Interrogatories and Requests for Production served on February 1, 2007.1 In accordance with RCFC 37, I affirm that I have attempted in good faith to resolve the matter contained in this motion, and that I have conferred or attempted to confer with Defendant's counsel in an effort to secure the information or material without action by this Court.

The Plaintiff also served Request for Admissions that have not been responded to and are deemed admitted pursuant to Rule 36, RCFC.

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Case 1:05-cv-00981-MMS

Document 24

Filed 03/26/2007

Page 2 of 2

Respectfully submitted. PEDERSEN & SCOTT, P.C.

S/William A. Scott William A. Scott 775 St. Andrews Blvd. Charleston, South Carolina 29407 (843) 556-5656 Fax (843) 556-5635 ATTORNEY FOR PLAINTIFF, K-CON BUILDING SYSTEMS, INC. Dated this 26th day of March , 2007.