MOTION FOR SANCTIONS

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                          IN THE DISTRICT COURT WITHIN AND FOR HUGHES COUNTY

STATE OF OKLAHOMA
FILED
IN RE THE MARRIAGE OF: )
JEANA MCBRIDE, ) JAN 13 2017
) PATTY
PETITIONER, _) Th
and ) CASE NO. FD-2013-40 unt Clerk
) PUTY
JUSTIN MCBRIDE, )
)
RESPONDENT.)

MOTION FOR SANCTIONS

COMES NOW, the Petitioner, by and through her attorney, M. Bradley Carter, pursuant to
12 OS. § 3237(B)(2), and moves the Court to enter an Order sanctioning the Respondent, Justin
McBride, and his attorney, Richard E. Butner, for failure to comply with discovery requests.

In support thereof, the Petitioner would show the Court as follows:

1. Counsel for Respondent was served with Petitioner’s Discovery Requests on the 22"?
day of September, 2016. All responses were due no later than the 22™ day of October, 2016;

2. Counsel conferred with opposing counsel on multiple attempts to acquire the
requested discovery but Respondent failed to submit the documents required. On November 23,
2016, Petitioner was required to file a Motion to C…