Motion to Enforce Court Order

DEFENDANT(S) MOTION TO ENFORCE COURT ORDER DATED _______ AND MOTION FOR SANCTIONS

Defendant(s), _________________, by and through the undersigned counsel, move(s) this Court for an Order Enforcing the Court Order dated __________ and entered into between the parties and as grounds state(s) the following:

1. On __________, the Honorable _____________ executed the Order on Defendant’s Motion to _________ and Motion to ____________and Motion to _________________. See Exhibit A.
2. On ____________, Defendant provided the Plaintiff with a copy of the executed Order. Defendant ___________________. See Exhibit B.
3. On ___________, Plaintiff’s counsel responded to the Defendant’s email: “_________________________.”  See Exhibit C.
4. On ___________, Defendant sent an identical Second Request  and the undersigned asked “___________”.  Plaintiff responded to Defendant’s email stating “___________.”  See Exhibit D.
5. As a result of Plaintiff failing to comply with the Court Order.  Defendant is forced to _________________ and ______________ are crucial to properly provide a defense.
6. Plaintiff has made no efforts to provide the information request in a timely matter.  Movant counsel further certifies that a bona fide effort to resolve the outstanding issues previously order by the Court be granted on behalf of the Defendant to narrow the issues on the foregoing Motion has been made with opposing counsel and award Sanction.

WHEREFORE, Defendant(s), ______________, respectfully request(s) that this Court enter an Order enforcing the Order  compelling Plaintiff(s) to _________________, awarding attorney’s fees and costs incurred in bringing this Motion, plus whatever further and additional relief this Court deems just and proper.