On December 28, 2009 a
Motion,Ex Parte
was filed
involving a dispute between
Green, Chris,
and
Collins, Robert J,
Robert J Collins Pc,
for PROFESSIONAL LIABILITY
in the District Court of Dallas County.
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Cause No. 09-17367
~
In THE 134™ DistrictAjourT
t wR Py
ep
CHRIS GREEN,
Plaintiff,
v.
Rosert J. COLLINS,
Defendant.
PLAINTIFF'S FIRST POST-JUDGMENT MOTION TO COMPEL
On July 21, 2011, Plaintiff served upon Defendant a post-judgment request for
production and a sct of post-judgment interrogatories. Defendant’s responses were duc on
August 23, 2011, but to date Plaintiff has yet to receive any responses or documents. All
objections have been waived as a matter operation of law.
WHEREFORE, Plaintiff move this Court for an order compelling Defendant to answer
Plaintiff's Post-Judgment Request for Production and Post-Judgment Interrogatories without
objection in writing within 10 days of the date of this order and further compelling Defendant to
deliver all responsive documents at Defendant’s expense to Plaintiff's counsel’s office within 10
days of the date of this order. Plaintiff further seeks sanctions in the amount of $500
tepresenting the cost of bringing this motion.
Respecif ly s) mitted,
David Bé Gibson
SBN 07861220
1801 N. Hampton Rd., Ste. 370
Desoto, TX 75115
(972) 291-9300
(972) 291-0636 Facsimile
COUNSEL FOR PLAINTIFF
PLAINTIFF'S FIRST POST-JUDGMENT MOTION TO COMPEL.THE GIBSON LAW GROUP
ATTORNEYS AT LAW
1801 N. Hampton Ro., STE. 370
DeSoto, TEXas 75115
my. lawyer@sbeglobal.net
Telephone (972) 291-9300
September 28, 2011
Via First CLASS MAIL
Clerk, 134" District Court
600 Commerce Street
Dallas, Texas 75202
Re: — Chris Green v. Robert J. Collins and Robert J. Collins, P.C.
Cause No. 09-17367
Dear Clerk:
Please file the enclosed Motion to Compel and return the file-stamped copy to me in the
enclosed SASE. The filing fee is enclosed as well.
Thank you.
Very trulyfou
f
Bob Collins
Document Filed Date
October 04, 2011
Case Filing Date
December 28, 2009
Category
PROFESSIONAL LIABILITY
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Cause No. 09-17367 ~ In THE 134™ DistrictAjourT t wR Py ep CHRIS GREEN, Plaintiff, v. Rosert J. COLLINS, Defendant. PLAINTIFF'S FIRST POST-JUDGMENT MOTION TO COMPEL On July 21, 2011, Plaintiff served upon Defendant a post-judgment request for production and a sct of post-judgment interrogatories. Defendant’s responses were duc on August 23, 2011, but to date Plaintiff has yet to receive any responses or documents. All objections have been waived as a matter operation of law. WHEREFORE, Plaintiff move this Court for an order compelling Defendant to answer Plaintiff's Post-Judgment Request for Production and Post-Judgment Interrogatories without objection in writing within 10 days of the date of this order and further compelling Defendant to deliver all responsive documents at Defendant’s expense to Plaintiff's counsel’s office within 10 days of the date of this order. Plaintiff further seeks sanctions in the amount of $500 tepresenting the cost of bringing this motion. Respecif ly s) mitted, David Bé Gibson SBN 07861220 1801 N. Hampton Rd., Ste. 370 Desoto, TX 75115 (972) 291-9300 (972) 291-0636 Facsimile COUNSEL FOR PLAINTIFF PLAINTIFF'S FIRST POST-JUDGMENT MOTION TO COMPEL.THE GIBSON LAW GROUP ATTORNEYS AT LAW 1801 N. Hampton Ro., STE. 370 DeSoto, TEXas 75115 my. lawyer@sbeglobal.net Telephone (972) 291-9300 September 28, 2011 Via First CLASS MAIL Clerk, 134" District Court 600 Commerce Street Dallas, Texas 75202 Re: — Chris Green v. Robert J. Collins and Robert J. Collins, P.C. Cause No. 09-17367 Dear Clerk: Please file the enclosed Motion to Compel and return the file-stamped copy to me in the enclosed SASE. The filing fee is enclosed as well. Thank you. Very trulyfou f Bob Collins