#Motion to dismiss template how to#

They can do this with a subpoena, not a blanket HIPAA authorization. Plaintiff’s Response to Motion to Compel Medical Records Authorization: Many defendants want to go around HIPAA and get the records from the medical providers.This motion requests a second deposition at defendant’s expense. Compel Deposition: Defense counsel with increased frequency instructs the defendant not to answer questions, usually because they don’t like the questions.Defendant’s Motion to Compel a Physical Exam (citing IME “handbook”).Another Response to Motion to Compel Physical Examination.The battle is usually over the conditions of the exam or the expert’s failure to provide financial information Response to Motion to Compel a Defense Medical Exam: We generally do not oppose the exam itself.

Normally, the response is just providing the answers. Compel Discovery Responses: Standard filing to get the other party to answer discovery.But there are some cases where it is absolutely necessary. Motion to Recuse Judge: You do not want to file a motion to recuse a judge very often.Our private investigator found that he did. This was a venue battle over the more specific factual issue of whether defendant was doing business in the jurisdiction in which we brought the claim. Opposition to Motion to Dismiss for Improper Venue: We have a lot of sample motions about venue because in Maryland, any in many jurisdictions, venue can make a real difference in settlement value.We won this motion and got a $5.5 million verdict Our response: This is our latest effort at fine-tuning our forum non conveniens arguments.

Maryland allows for alternative service if certain hoops have been jumped. Service by Alternative Method: Sometimes, you just can’t track down the defendant.Consolidate Cases: This is a motion to merge two related causes of action.

Motions Seeking and Opposing Summary Judgment.

#Motion to dismiss template how to#

These example motions can be used in whole or in part or may just give you ideas as to what might work for your pleading and how to write them. Sometimes, you have to reinvent the wheel when drafting legal documents but sometimes you do not. Below is a list of sample motions, responses to motions, and a few court orders.