Sample Motions

IN THE CIRCUIT COURT FOR PRINCE GEORGE’S COUNTY, MARYLAND

JANE DOE *
Plaintiff *
v. * Case No.:
JOHN SMITH *
Defendant *

MOTION TO COMPEL ANSWERS TO INTERROGATORIES

COMES NOW, the Plaintiff, Jane Doe, by and through her attorneys, FORAN & FORAN, P.A., and moves the Court for an order compelling the Defendant, John Smith, to furnish answers to interrogatories and for reasons therefore states as follows:

  1. The Plaintiff, Jane Doe, filed a Complaint with this Court on or about February 2, 2008.
  2. That the Defendant was served with interrogatories on or about February 15, 2008 (See attached as Exhibit A).
  3. That under Maryland Rule 2-421, the Defendant must serve a response to interrogatories within 30 days after service of the interrogatories or within 15 days after the date on which that party's initial pleading or motion is required, whichever is later.
  4. That under Maryland Rule 2-421, the Defendant’s answers to interrogatories were due on March 15, 2008.
  5. That in spite of ample time to answer said interrogatories, said answers have not been forthcoming from the Defendant.

WHEREFORE, the Plaintiff, Jane Doe, moves this Honorable Court for an order compelling the Defendant to provide full and complete responses to Plaintiff’s Interrogatories.

Respectfully Submitted,
FORAN & FORAN, P.A.


Ryan J. Foran
Attorneys for Plaintiff
6301 Ivy Lane, Suite 600
Greenbelt, Maryland 20770
301-441-2022

Motion for Sanctions

IN THE CIRCUIT COURT FOR PRINCE GEORGE’S COUNTY, MARYLAND

JANE DOE *
Plaintiff *
v. * Case No.:
JOHN SMITH *
Defendant *

MOTION FOR SANCTIONS

COMES NOW, the Plaintiff, Jane Doe, by and through her attorneys, FORAN & FORAN, P.A., and moves the Court for sanctions in the above matter and for reasons therefore states as follows:

  1. Defendant, John Smith, was served with the Complaint on January 27, 2008, and filed an answer to the lawsuit on February 14, 2008.
  2. On April 14, 2008, defendant Smith’s deposition was scheduled to be taken on April 28, 2008. (Exhibit A.) The deposition was rescheduled due to unavailability of the defendant.
  3. On April 28, 2008, defendant Smith’s deposition was rescheduled for May 18, 2008. (Exhibit B.) The deposition was rescheduled due to unavailability of the defendant.
  4. On May 5, 2008, defendant Smith’s deposition was rescheduled for June 6, 2008. (Exhibit C.) The Defendant, John Smith, failed to appear for his deposition on June 6, 2008.

WHEREFORE, Plaintiff prays as follows:

That the court enters such orders as are reasonable in this matter including:

  1. An order that the defendant, John Smith, appear for deposition within 30 days of the date of this order;
  2. An order denying the defendant, John Smith, the right to present any evidence at the trial of this matter on the issue of liability;
  3. An order for default judgment with regards to liability against the defendant, John Smith.
  4. Such other and further relief as the Court may deem just and proper.

Respectfully Submitted,
FORAN & FORAN, P.A.


Ryan J. Foran
Attorneys for Plaintiff
6301 Ivy Lane, Suite 600
Greenbelt, Maryland 20770
301-441-2022
District Court

Motion to Continue and Consolidate

IN THE DISTRICT COURT FOR PRINCE GEORGE’S COUNTY, MARYLAND

JANE DOE *
Plaintiff *
v. * Case No.: 1234-56780-2008
Trial Date 07/18/2008
JOHN SMITH * Defendant *
JANE DOE *
Plainitff *
v. * Case No.: 1234-56789-2008
Trial Date 10/6/08
DON SMITH *

MOTION TO CONTINUE AND CONSOLIDATE TRIAL DATES

COMES NOW, the Plaintiff, Jane Doe, by and through her attorneys, FORAN & FORAN, P.A., and respectfully requests this Honorable Court to continue the July 18, 2008, trial date against the Defendant, John Smith, and consolidate that trial date with the trial date set against the Defendant, Don Smith, which is currently set for October 6, 2008, and as reasons therefore, states as follows:

  1. This case arises out of an automobile tort claim between the Plaintiff, Jane Doe, and the Defendant, John Smith.
  2. That on or about April 1, 2008, the Plaintiff, Jane Doe, filed a complaint against the Defendant, John Smith.
  3. That trial is currently set against the Defendant, John Smith for July 18, 2008.
  4. That on or about July 2, 2008 the plaintiff filed an Amended Complaint naming an additional Defendant, Don Smith.
  5. The Trial Date against Don Smith is currently set for October 6, 2008.
  6. As the cause of the action set forth in the Amended Complaint against all Defendants arise out of the same automobile accident of January 1, 2008 the trial against all Defendants should be heard at one time, so that the rights and responsibilities of all the parties and interests can be determined at one time.

WHEREFORE, pursuant to Maryland Rules 3-503 and 3-508, the Plaintiff, John Smith, respectfully requests this Honorable Court consolidate and continue the July 18, 2008, trial date against the Defendant, John Smith, and set that trial at the same time and place as the trial date against the Defendant, Don Smith currently set for October 6, 2008.

Respectfully submitted,
FORAN & FORAN, P.A.


Ryan J. Foran
Attorney for the Plaintiff
6301 Ivy Lane, Suite 600
Greenbelt, MD 20770
(301) 441-2022

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