Motion to Compel PMQ Deposition (ROA 66)
The plaintiff filed a Notice of Withdrawal of her motion to compel the deposition of defendant’s Person Most Qualified and the production of documents. (ROA 70.)
The motion is, therefore, OFF CALENDAR.
Motion to Compel Production of Documents (ROA 55)
The plaintiff filed a motion to compel further responses from defendant Ford Motor Company to her Request for Production of Documents (Set One). In her reply, plaintiff withdraws her request as to Nos. 9, 11, 18-19, 22-23, and 37-38 based on the supplemental responses provided by Ford. As to those requests, the motion to compel is DENIED as MOOT.
As to the remaining requests—Nos. 21, and 33-35—the motion to compel is DENIED.
By statute, a notice of motion to compel further responses must be given within 45 days of the service of a verified response or any supplemental response or by any later date agreed to by the parties.
On the face of the motion, it was filed untimely, and the plaintiff fails to