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

Case 1:98-cv-00543-ECH

Document 135

Filed 03/11/2004

Page 1 of 2

UNITED STATES COURT OF FEDERAL CLAIMS ____________________________________ ) GOLD LINE REFINING, LTD., ) Through its Trustee Ben B. Floyd, ) ) Plaintiff, ) ) v. ) No. 98-543 ) (Judge Hewitt) THE UNITED STATES, ) ) Defendant. ) ____________________________________) PLAINTIFF'S MOTION TO COMPEL DEFENDANT TO ANSWER INTERROGATORIES AND RESPOND TO REQUEST FOR PRODUCTION OF DOCUMENTS Pursuant to Rule 37 of the Rules of the United States Court of Federal Claims ("RCFC"), Plaintiff moves this Court for an Order compelling Defendant to provide complete answers to Plaintiff's Third Set of Interrogatories and to provide documents responsive to Plaintiff's Third Request for Production of Documents. The grounds for this Motion are set forth in the attached Memorandum in Support of Plaintiff's Motion to Compel Defendant to Respond to Discovery. Therefore, Plaintiff respectfully requests that the Court issue an Order compelling service of complete and responsive answers and production of documents within five (5) days of the Court's Order. Respectfully submitted, s/ Ronald H. Uscher Ronald H. Uscher Bastianelli, Brown & Kelley, Chtd. Two Lafayette Centre 1133 21st Street, N.W., Suite 500 Washington, D.C. 20036

Case 1:98-cv-00543-ECH

Document 135

Filed 03/11/2004

Page 2 of 2

(202) 293-8815 (202) 293-7994 (fax) Counsel for Plaintiff Of Counsel: Donald A. Tobin Lori Ann Lange Bastianelli, Brown & Kelley, Chtd. Two Lafayette Centre 1133 21st Street, N.W. Suite 500 Washington, D.C. 20036 Dated: March 11, 2004 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 11th day of March 2004, the foregoing Plaintiff's Motion to Compel Defendant to Answer Interrogatories and Respond to Request for Production of Documents was filed electronically. I understand that notice of this filing will be sent to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system. s/ Ronald H. Uscher