IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
DONALD JONES, )
)
Plaintiff, )
)
v. ) Case No: 1:07-CV-0567-CC-RGV
)
WACKENHUT % GOOGLE INC., )
)
Defendant. )
DEFENDANT THE WACKENHUT CORPORATION’S
MOTION TO COMPEL
COMES NOW Defendant The Wackenhut Corporation (incorrectly
identified in Plaintiff’s Complaint as “Wackenhut % Google Inc.”) (hereinafter
“Defendant”), pursuant to Federal Rule of Civil Procedure 37 and Local Rule 37.1,
and hereby moves this Court for an Order: (a) compelling Plaintiff to supplement
his responses to Defendant’s First Set of Interrogatories and First Request for
Production of Documents; and (b) awarding Defendant its expenses and attorneys’
fees reasonably incurred in the preparation of this Motion.
In accordance with Federal Rule of Civil Procedure 37(a)(2)(B), counsel for
Defendant has in good faith conferred with Plaintiff, who is proceeding pro se, to
secure the requested information without the Court’s assistance. However, as
Case 1:07-cv-00567-CC-RGV Document 47 Filed 09/17/2007 Page 1 of 4
Jones v. Wackenhut % Google Inc. Doc. 47
Dockets.Justia.com
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discussed in more detail in the accompanying Memorandum of Law in Support of
this Motion, Plaintiff has failed to comply with Defendant’s requests.
WHEREFORE, for these reasons, Defendant respectfully requests that the
Court issue an Order granting its Motion to Compel.
Respectfully submitted this 17th day of September, 2007.
DUANE MORRIS LLP
/s/ James P. Ferguson, Jr.
Terry P. Finnerty
Georgia Bar No. 261561
James P. Ferguson, Jr.
Georgia Bar No. 258743
1180 West Peachtree Street
Suite 700
Atlanta, Georgia 30309
(404) 253-6900 (telephone)
(404) 253-6901 (facsimile)
Counsel for Defendant
The Wackenhut Corporation
Case 1:07-cv-00567-CC-RGV Document 47 Filed 09/17/2007 Page 2 of 4
DM2\1243867.1
CERTIFICATE OF COMPLIANCE
Pursuant to Local Rule 7.1(D), the undersigned counsel hereby certifies that
this filing complies with the type-volume limitations set forth in Rule 5.1 of the
Local Rules of the United States District Court for the Northern District of
Georgia. Counsel hereby states that this filing has been typed in Times New
Roman 14 font.
/s/ James P. Ferguson, Jr.
James P. Ferguson, Jr.
Case 1:07-cv-00567-CC-RGV Document 47 Filed 09/17/2007 Page 3 of 4
DM2\1243867.1
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
DONALD JONES, )
)
Plaintiff, )
)
v. ) Case No: 1:07-CV-0567-CC-RGV
)
WACKENHUT % GOOGLE INC., )
)
Defendant. )
CERTIFICATE OF SERVICE
I hereby certify that on this 17th day of September, 2007, I electronically
filed the foregoing DEFENDANT THE WACKENHUT CORPORATION’S
MOTION TO COMPEL with the Clerk of Court using the CM/ECF system.
I further certify that on this 17th day of September, 2007, I have mailed by
United States Postal Service the document to the following non-CM/ECF
participant:
Donald Jones
P.O. Box 261
Red Oak, Georgia 30272
/s/ James P. Ferguson, Jr.
James P. Ferguson, Jr.
Attorney for Defendant
The Wackenhut Corporation
Case 1:07-cv-00567-CC-RGV Document 47 Filed 09/17/2007 Page 4 of 4
