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Motion to Compel Probate

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT,
IN AND FOR MIAMI-DADE COUNTY, FLORIDA

Case No.: 11-xxxx-CP

IN RE: THE ESTATE OF Probate Division: 03

T.P.,
    Deceased.
______________________________/

Adversary Proceeding No. 12-855xxxx

P.S. AKA “P.S.”,
    Petitioner,
vs.
O.S.,
    Respondent.
______________________________/

RESPONDENT’S, O.S.’S, EX-PARTE MOTION TO COMPEL DISCOVERY

The Respondent, O.S., by and through undersigned counsel, moves this Honorable Court for an order compelling Petitioner, P.S. AKA “P.S.”, to respond to discovery request and states as follows:

1. That on June 20, 2012, Plaintiff served Petitioner, Interrogatories.

2. That no responses or objections have been filed by the Petitioner as of this date.

3. The information is material for the prosecution of this case.

WHEREFORE, pursuant to the applicable Florida Rules of Civil Procedure and Administrative Order, Plaintiff respectfully request that this Court to enter an Ex-Parte Order compelling the aforementioned discovery within ten (10) days from the date of this Order.

CERTIFICATE OF SERVICE

IT IS HEREBY CERTIFIED that on July 30, 2012, a true and correct copy of the foregoing was mailed by U.S. Mail to Esther T. Blynn, Esq., Law Offices of Blynn & Blynn, P.A., Biscayne Centre, 11900 Biscayne Boulevard, Suite 269, North Miami, FL 33181.

SACKRIN & TOLCHINSKY, P.A.
Attorneys for the Defendant(s)
2100 East Hallandale Beach Blvd., #200
Hallandale Beach, FL 33009
Telephone: (954) 458-8655
Facsimile: (954) 455-3388

By__________________________________________
ALAN D. SACKRIN, ESQ. Florida Bar No. 349070
LARRY TOLCHINSKY, ESQ. Florida Bar No 021997

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IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT,
IN AND FOR MIAMI-DADE COUNTY, FLORIDA

Case No.: 11-xxxx-CP

IN RE: THE ESTATE OF Probate Division: 03

T.P.,
    Deceased.
______________________________/

Adversary Proceeding No. 12-855xxxx

P.S. AKA “P.S.”,
    Petitioner,
vs.
O.S.,
    Respondent.
______________________________/

EX PARTE ORDER ON THE RESPONDENT, O.S. MOTION TO COMPEL DISCOVERY

THIS CAUSE having come on to be heard on the Respondent, O.S., Ex Parte Motion to Compel Discovery, and the Court having considered same, under Local Rule, and being otherwise duly advised in the premises, it is

ORDERED AND ADJUDGED that the Ex Parte Motion to Compel Discovery be and the same is hereby granted and the Respondent, O.S., is to respond within ten (10) days from the date of this Order. 

DONE AND ORDERED at Miami-Dade County, Florida, this ____ day of ________________, 20___.

______________________________
CIRCUIT JUDGE

Copies furnished:

Alan D. Sackrin, Esq.
Larry Tolchinsky, Esq.
Esther T. Blynn, Esq.

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This is a sample lawsuit related to a specific set of facts and circumstances and should not be used or relied upon for any probate matter. We recommend and urge you to consult with an experienced lawyer for professional advice as each case is unique.

 

 

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