Motion,Ex Parte: Cheryle Adams VS Terry Partridge , defendant, et al

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                                ELECTRONICALLY FILED - 2023 Jul 18 1:23 PM - ABBEVILLE - COMMON PLEAS - CASE#2023CP0100005
STATE OF SOUTH CAROLINA                )      IN THE COURT OF COMMON PLEAS
COUNTY OF ABBEVILLE                    )      C.A. NO.: 2023-CP-01-00005

CHERYLE ADAMS,                )
                              )
       Plaintiff,             )
                              )                       MOTION TO COMPEL
vs.                           )
                              )
TERRY PARTRIDGE, Individually )
and as Employee/Agent of C&M  )
Associates of SC, LLC,; C&M   )
ASSOCIATES OF SC, LLC,        )
                              )
       Defendants.            )
______________________________)

TO:    PLAINTIFF AND HIS ATTORNEY OF RECORD:

       YOU WILL PLEASE TAKE NOTICE that ten (10) days after the service hereof, or at

such time and place as the court may deem appropriate, the defendant will move the Court,

pursuant to Rule 37 of the South Carolina Rules of Civil Procedure, for an Order compelling the

plaintiff to answer Interrogatories and respond to Requests for Production of Documents in the

above-entitled action.

       The grounds for said motion are that said Interrogatories and Requests for Production

were served on the plaintiff on or about on April 13, 2023, that the plaintiff has failed to provide

answers to Interrogatories and responses to Requests for Production or objections to the same

and, therefore, this defendant is entitled to the requested information as a matter of law.

       This defendant submits the Interrogatories and Requests for Production at issue in this

case, and such memorandum of law as may be filed with the court prior to the hearing of this

motion, in support hereof.



                               (Signature page to follow)
                                                                                                    ELECTRONICALLY FILED - 2023 Jul 18 1:23 PM - ABBEVILLE - COMMON PLEAS - CASE#2023CP0100005
                             CLARKSON, WALSH, & COULTER, P.A.


                                     By:_____s/Michael T. Coulter__________
                                     Michael T. Coulter (SC Bar# 15177)
                                     P.O. Box 6728
                                     Greenville, SC 29606
                                     (864) 232-4400
                                     (864) 235-4399 – fax
                                     Attorneys for defendant

Greenville, South Carolina
July 18, 2023

       In accordance with Rule 11 of the South Carolina Rules of Civil Procedure, I affirm that I

have communicated with opposing counsel and have attempted in good faith to resolve the

matter contained in the motion.


                                            ____s/Michael T. Coulter______________
                                            Michael T. Coulter