Several months have passed and the Managing Partner approved and properly filed the Complaint and properly submitted the Request for Production of Documentsthat you drafted. In fact, it has been 75 days since she served the Miller's Fun Park's attorneys with theRequest for Production of Documents and she has not received a response. The Managing Partner indicated that she sent a letter to the opposing counsel requesting a response in 30 days. She did this as a good faith attempt. However, the 30 days have passed and we still have not received any response to the Request for Production of Documents.

The Managing Partner has asked you to draft a Motion to Compel seeking the court to compel Miller's Fun Park to respond to theRequest for Production of Documents within 30 days. The Managing Partner asked you to draft all parts of the motion (including a Memorandum of Law that describes why the court should grant the Motion to Compel). Please use LEXIS+ to find the applicable court regulation in your state of residence that provides the basis for aMotion to Compel. Also, please refer to your state of residence to determine the form and requirements for a Motion to Compel. Remember to include appropriate captions. If required, please use the same addresses for the parties that you used when drafting the Complaint. The name of the judge in the case is the Honorable Cynthia Walsch.