Defendant Johnson filed a Motion to Compel Plaintiff to provide documents requested in Defendant's First Request for Production of Documents. Plaintiff failed to provide any documents or written responses by the due date of February 18th, 2016. Defendant Johnson's attorney has conferred with Plaintiff's attorney but Plaintiff has not produced the requested documents. Defendant Johnson is seeking an order from the court compelling Plaintiff to allow inspection of the requested documents and is also seeking reimbursement of attorney's fees for bringing this motion.

1. IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT,
IN AND FOR BROWARD COUNTY, FLORIDA
LINDA SMITH,
Plaintiff,
vs.
Civil Action No. XXXXXXXXXX
SAM JOHNSON, and
KEVIN ROBERTS,
Defendants.
_________________________________/
DEFENDANT’S MOTION TO COMPEL
Defendant Johnson (“Defendant Johnson”), as pursuant to Rules 1.350(b) and 1.380(a)(2) of
the Florida Rules of Civil Procedure, move for an order compelling Plaintiff to allow inspection
of the documents requested in Defendant Johnson’s First Request for Production of Documents,
and in support thereof state:
1. Defendant Johnson served Plaintiff with Defendant’s First Request for Production of
Documents, together with other discovery requests, upon Plaintiff on January 14th
2016. (Copy
attached as Exhibit 1).
2. Allowing 30 days for service of response as set forth in Rule 1.350(b) and an additional 5
mailing days as allowed by Rule 1.090(e). Plaintiff’s response was due on February 18th
2016.
Plaintiff provided no discovery responses by that date.
3. To date, Plaintiff has provided no written response not documents in response to Defendant
Johnson’s First Request for Production of Documents.
4. According to the parties’ stipulated scheduling order, Defendant’s motion for summary
judgment Is due in 14 days from the filing of this motion; Defendant will be prejudiced by having
to file their motion without the discovery materials to which they were entitled.

2. 5. Defendant Johnson’s counsel, in good faith, has conferred with Plaintiff’s counsel to secure
the documents requested without court action. Unfortunately, these efforts have been unavailing
as Plaintiff has neither produced the requested documents nor indicated when they expect to do
so.
6. Pursuant to Rule 1.380(a)(4) of the Florida Rules of Civil Procedure, Defendant’s seek to
recover their reasonable expenses, including attorney’s fees, incurred in obtaining an order from
the Court granting Defendant’s Motion to Compel.
WHEREFORE, Defendant Johnson respectfully requests that this court enter in an order
compelling Plaintiff forthwith to allow inspection of the documents requested in Defendant
Johnson’s First Request for Production of Documents, and award Defendant Johnson’s attorney’s
fees for bringing this motion, and grant such further relief as the Court deems appropriate.
_________________________________________
Allison Wright
Wright’s Legal Services
10921 North Federal Highway.
Fort Lauderdale, Florida 33304
FL Bar No. XXXXXXXXXX
Attorney for Defendant Sam Johnson

3. CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy has been provided by electronic mail on this 19th
day
of February, 2016, to:
Joshua Wieczorek
Joshua D. Wieczorek, Esq.
PO Box 30082
Fort Lauderdale, Florida 33303
FL Bar No. 89883100
Attorney for Plaintiff
Alison Wright aAllison Wright