Motion to Compel - Due Date: Complete Date:

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                          Filing # 23164666 E-Filed 01/30/2015 08:36:03 AM

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA

LEONOR PEREZ BARRIL, CIRCUIT CIVIL DIVISION
Plaintiff, CASE NO.: 13-031784 CA 01

VS.

DOUGLAS SCHROCK AND JESSICA Florida Bar No.: 747483

SCHROCK,

Defendants.
i

DEFENDANTS' MOTION TO COMPEL DISCOVERY
Defendants, JESSICA SCHROCK AND DOUGLAS SCHROCK, by and through their
undersigned attorneys, move this Court for an Order compelling the Plaintiff, LEONOR PEREZ-
BARRIL, to answer the Interrogatories and Request for Production, in accordance with Rule
1.380, Florida Rules of Civil Procedure, upon the following grounds:
1.Interrogatories and Request for Production were propounded to the Plaintiff on October
31, 2014, and response thereto was due on December 5, 2014
2.To date, Plaintiff has not responded to the Request for Production nor answered the
Interrogatories, nor objected to same and no extension of time has been requested by Plantiff.
3.…