Document for 13-DR-0038 - MASSIE, CURT A vs. MASSIE, RHONDA L

• 
• 
• 
• 
• 
• 

                        

						    Preview
                        
                        
                          y y

IN THE COURT OF COMMON PLEAS
FOR WAYNE COUNTY, OHIO ec
DOMESTIC RELATIONS DIVISION

3

CURT MASSIE CASE NO.: 13-DR-0038

Plaintiff JUDGE WIEST
. MAGISTRATE BAUDERS
RHONDA MASSIE

DEEFENDANT’S MOTION TO
COMPEL AND MOTION FOR
SANCTIONS AND MEMORANDUM
IN SUPPORT

Defendant

Now comes the Defendant, Rhonda Massie, by and through her undersigned counsel, and
moves this Honorable Court for an Order compelling the Plaintiff, Curt Massie to submit to
responses to Defendant's First Set of Interrogatories and Request for Production of Documents
propounded upon Plaintiff.

As sanctions, Defendant requests an Order compelling the Plaintiff or Plaintiff's counsel
to pay to Plaintiff's counsel the total sum of nine-hundred fifteen Dollars ($915.00) representing
three (3.0) hour’s worth of time associated with putting together this Motion to Compel and
Motion for Sanctions, an additional three (3.1) hours spent drafting letters, drafting e-mails and
engaging in telephone conversations with Plai…