MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES (SET ONE)

MOVING PARTY: Plaintiff Richard Pech

RESPONDING PARTY(S): Defendant Thomas E. Morgan, III

PROOF OF SERVICE:

ANALYSIS

Motion to Compel Further Responses to Special Interrogatories

This motion was timely served and filed on June 29, 2019, prior to the July 25, 2019 deadline to which the parties agreed. Pech Decl., ¶ 12; Exh. 7.

However, the Court agrees with Defendant that Plaintiff did not allow Defendant sufficient time to serve supplemental responses as part of the meet and confer process. The parties agreed that the deadline to file this motion would be July 25, 2019. Yet, Plaintiff filed this motion on June 27, 2019—nearly a month before the deadline to file this motion.

As Defendant’s counsel represents, he was out of town during the June 17, 2019 demanded by Plaintiff’s counsel. Furman Decl., ¶........