IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF FLORIDA
PENSACOLA DIVISION

WARD DEAN,	)
	)
Plaintiff,	)
	)
v.	)	No.3 :03 cv 00065 (LAC/MCR)
	)
UNITED STATES, et al.,	)
	)
Defendants.	)
	)

PLAINTIFF’S MOTION TO COMPEL THE PRODUCTION OF DISCOVERY MATERIALS

COMES NOW your Plaintiff, Ward Dean, to move this Court pursuant to Federal Rule of Civil Procedure 37(a)(3) to order the Defendant to respond to Plaintiff’s discovery requests with answers and documents that are responsive to those requests.

Plaintiff served the government with his discovery requests in a timely manner. The government responded with evasive or obfuscative answers, or refused to respond altogether. Appended as Exhibits 1-6 are Plaintiff’s Requests for the Production of Documents, Requests for Admissions and Interrogatories. Defendant has responded only to the Requests for Admissions (Exhibits 7 and 8), and in each case only to object to each admission.

Plaintiff would move this Court to order production of the requested discovery by a date certain, so the Court will have adequate time to determine if any of the requested discovery requires redaction, and whether the objections to the admissions should be upheld.

Plaintiff has conferred with opposing counsel in a good faith effort to resolve this issue and counsel is unwilling to provide any discovery other than that already provided

Respectfully submitted,

_______________________
Ward Dean, M.D. / Pro se

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the day of October, 2003, I have placed a true and exact copy of the foregoing in the U. S. Mail, first class postage, prepaid, addressed to:

Lindsey W. Cooper, Jr.
Civil Tax, Eastern Region
U.S. Department of Justice
P .0. Box 227, Ben Franklin Station Washington, DC 20044

______________________
Ward Dean, M.D.

 

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