Defendant's Motion To Dismiss and Supporting Suggestion
Defendant's Motion To Dismiss and Supporting Suggestion
OF STATE PLAINTIFF, Plaintiff, vs. DEFENDANT Defendant(s). ) ) ) ) ) Cause No. CAUSE NO Div/Team No. DIVISION
DEFENDANTS MOTION TO DISMISS AND SUPPORTING SUGGESTIONS COMES NOW Defendant, DEFENDANT, and hereby moves this Court to dismiss this matter as Plaintiff, PLAINTIFF, has failed to respond to Defendants Request for Production of Documents Directed to Plaintiff within the # (MISSOURI: 30) day allowance for litigant response to Discovery, as set forth in STATE Rules of Procedure. In support of motion, Defendant offers the following: Defendant has timely responded to all Plaintiffs Requests and Interrogatories, and has cooperated with all Court summons concerning Plaintiffs complaint, yet to be validated by Plaintiff.
Plaintiff has failed to timely respond to Defendants Request for Production of Documents and
Debt Validation inquiry within the # (MISSOURI: 30) day allowance for litigant response to Discovery, as set forth in STATE Rules of Procedure.
Plaintiff has brought suit to the honorable Court, yet has failed to illustrate to the Court the
validity of the alleged debt. Plaintiff has not taken the responsibility to pursue this suit within the STATE Rules of Procedure, but rather attempts to collect monetarily through default judgment, a perverse manipulation of the justice system. Lacking appropriate and sufficient evidence to implicate Defendant, relief cannot be granted. Defendant respectfully requests that this matter be dismissed.
A copy of the foregoing mailed this DATE, to: PLAINTIFF, ADDRESS. ______________________________ DEFENDANT