Motion,Ex Parte: Mark C. Boyles, Individually , plaintiff, et al VS Ncp Bayou, Llc

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                                ELECTRONICALLY FILED - 2023 Mar 20 11:50 AM - JASPER - COMMON PLEAS - CASE#2023CP2700001
STATE OF SOUTH CAROLINA                        )     IN THE COURT OF COMMON PLEAS
                                               )     FOURTEENTH JUDICIAL CIRCUIT
COUNTY OF JASPER                               )     CASE NO.: 2023-CP-27-0001

Mark C. Boyles, Individually and as Personal )
Representative of the Estate of Grace Laverne )
Boyles,                                       )
                                              )
                      Plaintiff,              )
                                              )
vs.                                           )      DEFENDANT’S MOTION TO COMPEL
                                              )      DISCOVERY RESPONSES FROM
NCP Bayou, LLC,                               )      PLAINTIFF
                                              )
                      Defendant.              )
                                              )

TO:    THE DEFENDANT MARK C. BOYLES, INDIVIDUALLY AND AS PERSONAL
       REPRESENTATIVE OF THE ESTATE OF GRACE LAVERNE BOYLES AND
       HIS ATTORNEY, F. TRUETT NETTLES II, ESQUIRE:


       YOU WILL PLEASE TAKE NOTICE that Defendant NCP Bayou, LLC (“NCP”), by and

through its undersigned counsel, pursuant to Rule 37, SCRCP, hereby requests the Court to issue

an Order compelling Plaintiff Mark C. Boyles, Individually and as Personal Representative of the

Estate of Grace Laverne Boyles, to respond to the following discovery requests, served January

16, 2023:

       1.      Defendant’s First Interrogatories to Plaintiff, dated January 16, 2023 (Exhibit 1);

       2.      Defendant’s First Requests for Production to Plaintiff, dated January 16, 2023

               (Exhibit 2).

       Said discovery responses were initially due on or before February 15, 2023. To date,

Plaintiff has not provided any responses.
                                                                                                                                      ELECTRONICALLY FILED - 2023 Mar 20 11:50 AM - JASPER - COMMON PLEAS - CASE#2023CP2700001
          The Defendant, pursuant to Rule 11, SCRCP, has consulted with Defendant’s counsel as

to the resolution of this Motion prior to filing same, without success.



                                                               RUSSELL P. PATTERSON, P.A.


                                                               /s/ Lauren P. Williams
                                                               Russell P. Patterson
                                                               Lauren P. Williams
                                                               P.O. Drawer 8047
                                                               Hilton Head Island, SC 29938
                                                               (843) 341-9300
                                                               russell@russellpattersonlaw.com
                                                               lauren@russellpattersonlaw.com
                                                               Attorneys for the Defendants


March 20, 2023
Hilton Head Island, SC




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F:\Russell\Northlight Capital Partners - Carolina Timber- Boyles\Pleadings- Suit to Void LE Deed 1-23\Motion to Compel 3-17-23.docx