Other side's late/poor responses to my discovery requests.... Form interrogatories and requests for production of documents. TY

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Other side's late/poor responses to my discovery requests.... Form interrogatories and requests for production of documents. TY

Anonymous Feb 20, 2016 Business 3 views 2 answers

I, just today, received a discovery answer package with $2 worth of postage on it in response to my discovery answer package with $10 worth of postage on it. Inside was a bunch of objections to my requests for discovery. They were due yesterday. 30days +5 for mailing. He sent them to the wrong address and is pretending to be ignorant of my new address (even though I have given it to him several times in the past and updated the court with it 4+ months ago). He also wrote many times that he enclosed things (like photographs) "produced herewith" but they are nowhere to be found. Why not? He actually inadvertently ended up with my original (with no copies) of a photograph and I need it back ASAP and he is claiming he sent it but did not. The same goes for an audio file/report that he has and claims he has attached but did not. I sent him a meet and confer letter yesterday signifying that he missed the deadline and that he can no longer object to my questions/requests. WHAT can I do?!? Motion for sanctions? Motion to Compel? He appears to be really screwing up yet gaming me big time. I met the deadline, he did not. I produced his demanded documentation, he has not. TY

Bryan Smith · Accepted Answer · 2026-06-15T17:05:44+00:00

Assuming you are not approaching the discovery cutoff date, you have 45 days from the date the responses were served to file a motion to compel. That means you should prepare a meet and confer letter at the earliest opportunity, unless the two of you can stipulate to a later deadline in exchange for allowing him additional time to respond. It's usually a good practice to include the text of the entire separate statement in the meet and confer letter: for each insufficient response you would quote the discovery item, the response, and explain the reason a further response is needed, including any supporting statutory and case law. It may be worth your time to retain an attorney on a limited scope basis. If sanctions are awarded (they not always are), they will be based on the attorney's time and billing rate.

Nicholas Spirtos · Accepted Answer · 2026-06-15T17:05:44+00:00

Your interpretation of the deadline may be incorrect. To know for sure would require a consultation and review of the relevant documents. Since you sent a meet and confer letter already, the next step would be to file a motion to compel responses or further responses and let the court decide. There are a lot of possibilities with your situation and discovery can be complex. The amount of postage on your package versus his is completely irrelevant, and also indicates that you may be focusing on the wrong issues. Go see an attorney. You need some help here.

Other side's late/poor responses to my discovery requests.... Form interrogatories and requests for production of documents. TY

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