Facts: And the following facts:

• Tony Smulder. Mr. Smulder received a promotion at work last week. To celebrate, he went to dinner with his brother, Nick, and had a few bottles of wine. When it was time to leave, Tony felt fine to drive. He was headed home on the expressway, listening to his favorite radio station, when he realized he was about to miss his exit. He swerved over a few lanes to exit the expressway.
• Unfortunately for Tony, a police officer was behind him and pulled him over as he was exiting the expressway. Tony was administered a field sobriety test, which was inconclusive. He then was administered a breathalyzer test. The test came back showing Tony's blood alcohol content was just over the legal limit. Tony was arrested and charged with driving under the influence. This was his third DUI, and he is now worried about the repercussions.
• Your supervising attorney thinks the case should be dismissed because the complaint fails to mention the exact blood alcohol level (.08). As the field sobriety test was inconclusive, your supervising attorney believes that the complaint was deficient. You should research and use the laws of your state pertaining to the elements for DUI in crafting the motion. The case was filed in the Springfield Minnesota District Court.

We are in the middle of the discovery phase in Tony's case, and the prosecutor is being slow in providing information pertaining to the breathalyzer exam and the breathalyzer itself. Specifically, we requested the make and model of the breathalyzer, as well as the records of any maintenance on the machine itself. We also requested the certified results of the breathalyzer exam. We have requested the information from the state previously and received a one page summary of the blood alcohol level of our client, but the certified results were not presented. We also have no response to the rest of our requests as of yet, and it has been over 3 months. I would like you to wriite a motion to compel for my review. A template has been provided for you here.

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF KENTUCKY

CENTRAL DIVISION AT LEXINGTON

JEFF NELSON Plaintiff v. THE WIDGET CO. Defendant	* * * * * * * * *	Case No. Judge DEFENDANT'S MOTION TO COMPEL ATTORNEY Attorney for Plaintiff Jeff Nelson
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DEFENDANT, by and through undersigned counsel and pursuant to Rule 3.220(n), Florida Rules of Criminal Procedure, requests this Court to enter an Order compelling the State of Florida to comply with the various rules of discovery outlined in Rule 3.220. As grounds for this Motion, Defendant states as follows:

On DATE, Defendant served the State of Florida with a Notice of Discovery pursuant to Rule 3.220, Florida Rules of Criminal Procedure.

Defendant contends that the State of Florida's response to Defendant's Notice of Discovery is legally insufficient and non-compliant with Rule 3.220 for the reasons set forth below:

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WHEREFORE, Defendant respectfully requests that this Court enter an Order requiring the State disclose or specify the information or documents described herein.

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ATTORNEY

Attorney for Plaintiff

NOTICE OF SERVICE

I hereby certify that a copy of the foregoing was filed this ____ day of February, 2012, electronically. Notice of this filing was sent to all parties by operation of the Court's electronic filing system. Parties may access the filing through the Court's system.

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