On January 02, 2023 a
Motion,Ex Parte
was filed
involving a dispute between
Saunders, Edna Marie,
and
Robinson, Kathy Marie,
for Common Pleas
in the District Court of Fairfield County.
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ELECTRONICALLY FILED - 2023 Aug 28 2:30 PM - FAIRFIELD - COMMON PLEAS - CASE#2023CP2000001
STATE OF SOUTH CAROLINA )
) IN THE COURT OF COMMON PLEAS
COUNTY OF FAIRFIELD )
)
EDNA MARIE SAUNDERS, ) Civil Action No. 2023CP2000001
)
Plaintiff, )
)
vs. ) NOTICE OF MOTION AND
) MOTION TO COMPEL DISCOVERY
KATHY MARIE ROBINSON, )
)
Defendant. )
TO: PLAINTIFF AND ELEAZER R. CARTER, ESQUIRE, ATTORNEY FOR PLAINTIFF:
YOU WILL PLEASE TAKE NOTICE that the Defendant, Kathy Marie Robinson, by
and through the undersigned attorneys, will move before the Presiding Judge, ten (10) days after
the service of this Notice, or at such time as counsel is scheduled to be heard, for an Order
pursuant to Rule 37 of the South Carolina Rules of Civil Procedure compelling the Plaintiff to
respond to discovery requests served on her by Defendant, Kathy Marie Robinson, on May 10,
2023. These requests consisted of 39 interrogatories and 12 requests for production, to which
Plaintiff has not responded. Defendant, Kathy Marie Robinson, request reasonable attorney’s
fees and costs for bringing this motion.
Defendant's counsel affirms that by letter of July 12, 2023, counsel for Plaintiff was
contacted in a good faith effort to resolve this motion.
ELECTRONICALLY FILED - 2023 Aug 28 2:30 PM - FAIRFIELD - COMMON PLEAS - CASE#2023CP2000001
Respectfully submitted,
s/ S. Carson Shealy
S. CARSON SHEALY (SC Bar No. 104746)
Carson.Shealy@mgclaw.com
RILEY A. BEARDEN (SC Bar No. 104332)
riley.bearden@mgclaw.com
Post Office Box 12519
1320 Main Street, 10th Floor (29201)
Columbia, South Carolina 29211
Telephone: (803) 779-2300
Facsimile: (803) 748-0526
ATTORNEYS FOR KATHY MARIE ROBINSON
August 28, 2023
Columbia, South Carolina
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ELECTRONICALLY FILED - 2023 Aug 28 2:30 PM - FAIRFIELD - COMMON PLEAS - CASE#2023CP2000001 STATE OF SOUTH CAROLINA ) ) IN THE COURT OF COMMON PLEAS COUNTY OF FAIRFIELD ) ) EDNA MARIE SAUNDERS, ) Civil Action No. 2023CP2000001 ) Plaintiff, ) ) vs. ) NOTICE OF MOTION AND ) MOTION TO COMPEL DISCOVERY KATHY MARIE ROBINSON, ) ) Defendant. ) TO: PLAINTIFF AND ELEAZER R. CARTER, ESQUIRE, ATTORNEY FOR PLAINTIFF: YOU WILL PLEASE TAKE NOTICE that the Defendant, Kathy Marie Robinson, by and through the undersigned attorneys, will move before the Presiding Judge, ten (10) days after the service of this Notice, or at such time as counsel is scheduled to be heard, for an Order pursuant to Rule 37 of the South Carolina Rules of Civil Procedure compelling the Plaintiff to respond to discovery requests served on her by Defendant, Kathy Marie Robinson, on May 10, 2023. These requests consisted of 39 interrogatories and 12 requests for production, to which Plaintiff has not responded. Defendant, Kathy Marie Robinson, request reasonable attorney’s fees and costs for bringing this motion. Defendant's counsel affirms that by letter of July 12, 2023, counsel for Plaintiff was contacted in a good faith effort to resolve this motion. ELECTRONICALLY FILED - 2023 Aug 28 2:30 PM - FAIRFIELD - COMMON PLEAS - CASE#2023CP2000001 Respectfully submitted, s/ S. Carson Shealy S. CARSON SHEALY (SC Bar No. 104746) Carson.Shealy@mgclaw.com RILEY A. BEARDEN (SC Bar No. 104332) riley.bearden@mgclaw.com Post Office Box 12519 1320 Main Street, 10th Floor (29201) Columbia, South Carolina 29211 Telephone: (803) 779-2300 Facsimile: (803) 748-0526 ATTORNEYS FOR KATHY MARIE ROBINSON August 28, 2023 Columbia, South Carolina