Assume that your firm, Stahl & Beetum, PC , 13 Sol St., Wigmore, IL 00001, served the interrogatories and Notice to Produce on Plaintiff’s attorney. The Wigmore Supreme Court Rule 213 Written Interrogatories to Parties subsection (d) requires the opposing party to answer the interrogatories within 28 days of receipt. The Wigmore Supreme Court Rule 214 Discovery of Documents subsection (a) requires that the opposing party tender the requested documents within 28 days of receipt of the Notice to Produce. The Wigmore Supreme Court Rules are provided here.
Your supervising attorney, B. G. Brothers tells you that she served Interrogatories and a Notice to Produce on Plaintiff’s counsel over 120 days ago. She further tells you that she has had two personal conferences with Plaintiff’s counsel, Rich N. Moore, requesting that he immediately provide his client’s responses to both discovery requests. In both conferences Mr. Moore promised to serve his client’s responses to both discovery requests within two weeks, but he has not done so. Brothers tells you she is tired of waiting and getting empty promises from Plaintiff’s counsel. She asks you to draft a Motion to Compel Plaintiff’s Answers to Written Discovery. She tells you to review the applicable Wigmore Supreme Court Rules on discovery and then hands you a document with the applicable rules. It is attached here.
Ms. Brothers tells you to read and include in your motion citation to and a discussion of case law. She says you may use Transamerica Ins. Group v. Lee, 164 Ill. App. 3d 945, 518 N.E.2d 413 (1987), Mueller v. Insurance Ben. Admrs., Inc., 175 Ill. App. 3d 587, 529 N.E.2d 1126 (1988), or such other case you may believe appropriate. She says the Motion is due by Sunday at 1159pm. She also gives you a form for a Motion to Compel that she has from her prior firm which was a Plaintiff’s firm.