Assume that your firm, Stahl & Beetum, PC ,13 Sol St., Wigmore, IL 00001, served the interrogatories and Notice toProduce on Plaintiff's attorney. The Wigmore Supreme Court Rule 213 Written Interrogatoriesto Parties subsection (d) requires the opposing party to answer theinterrogatories within 28 days of receipt. The Wigmore Supreme CourtRule 214 Discovery of Documents subsection (a) requires thatthe opposing party tender the requested documents within 28 days ofreceipt of the Notice to Produce. The Wigmore Supreme Court Rules areprovided here.

Your supervising attorney, B. G. Brothers tells you that she servedInterrogatories and a Notice to Produce on Plaintiff's counsel over 120days ago. She further tells you that she has had two personalconferences with Plaintiff's counsel, Rich N. Moore, requesting that heimmediately provide his client's responses to both discovery requests.In both conferences Mr. Moore promised to serve his client's responsesto both discovery requests within two weeks, but he has not done so.Brothers tells you she is tired of waiting and getting empty promisesfrom Plaintiff's counsel. She asks you to draft a Motion to CompelPlaintiff's Answers to Written Discovery. She tells you to review theapplicable Wigmore Supreme Court Rules on discovery and then hands you adocument with the applicable rules. It is attached here.

Ms. Brothers tells you to read and include in your motion citation toand a discussion of case law. She says you may use Transamerica Ins.Group v. Lee, 164 Ill. App. 3d 945, 518 N.E.2d 413 (1987), Mueller v.Insurance Ben. Admrs., Inc., 175 Ill. App. 3d 587, 529 N.E.2d 1126(1988), or such other case you may believe appropriate. She says theMotion is due by Sunday at 1159pm. She also gives you a form for a Motion to Compel that she has from her prior firm which was a Plaintiff's firm.