IN THE SUPERIOR COURT OF THE
STATE OF RIDGEWAY
ASPENFUN,
Plaintiff,
v,
MASTERQV,
Defendant.
PLAINTIFF’S MOTION TO COMPEL
RESPONSES TO INTERROGATORIES,
REQUESTS FOR PRODUCTION, AND
REQUESTS FOR ADMISSION
Hon. Mytrius
Docket Number: RSC-CV-8952
INTRODUCTION
COMES NOW the Plaintiff, Mr. aspenfun, by and through the undersigned attorney,
respectfully moves this Honorable Court under Rule 26.3 of the Ridgeway Rules of Civil
Procedure for an order compelling Defendant to answer Plaintiff’s Request for
Admissions RFA Nos. 1-22; to answer Plaintiff’s Interrogatories Nos. 1-14; and to
respond to and produce materials responsive to Plaintiff’s Request for Production RFP
Nos. 1-9. In support thereof, Plaintiff states as follows:
BACKGROUND
1. On August 4, 2026, at 12:09pm UTC, Plaintiff timely served Plaintiff’s First Set of
Discovery in this action to the Defendant’s attorney through Direct Message in an attempt
to confer. The discovery included fourteen interrogatories, twenty-two requests for
admissions, and nine requests for production.
——————————————————————————————————————————————
PLAINTIFF'S MOTION TO COMPEL
- 1 -
2. The interrogatories and requests for admission seek to shorten the length of a trial by
admitting to some facts. Additionally, these requests seek to understand the defence of
the Defendant at trial, and their perspective on the alleged facts of the Complaint.
3. The request for production seeks to produce any ESI the Defendant may be in possession
of that would be introduced at trial.
4. To date, the Defendant’s attorney has ignored these requests, and has not conferred with
Plaintiff’s attorney. Defendant has not produced, or otherwise answered to any of these
requests, and has not objected to any.
5. The outstanding discovery therefore remains unresolved despite Plaintiff’s good-faith
effort.
ARGUMENT
I. RULE 26.3 AUTHORIZES AN ORDER COMPELLING THE OUTSTANDING
ANSWERS AND PRODUCTION
6. Rule 26.3(3) authorizes a motion to compel under six specific circumstances. Here,
Defendant meets four of those circumstances.
7. Specifically:
a. 26.3(3)(3): Defendant has failed to answer all fourteen interrogatories served
under Rule 21;
b. 26.3(3)(4): Defendant has failed to produce any ESI under Rule 26;
c. 26.3(3)(5): Defendant has failed to serve an answer or sufficient answer to all
twenty-two requests for admission under Rule 26.1; and,
——————————————————————————————————————————————
PLAINTIFF'S MOTION TO COMPEL
- 2 -
d. 26.3(3)(6): Defendant has failed to make disclosure as required by Rule 19.1,
despite the fact Plaintiff has made disclosure already.
8. The requested discovery is legitimate, and asks for relevant answers. The requests relate
to the actual incident itself, including whether or not Defendant asserts self-defence,
whether or not Defendant was actually there, and what evidence the Defendant intends to
present at trial. Along with their lack of answers, Defendant has not objected to any of
these requests.
9. Accordingly, Defendant should be ordered to serve complete answers to the requests
within forty-eight hours.
CONCLUSION
10. WHEREFORE, Plaintiff respectfully requests that the Court:
a. Order Defendant to serve complete, request-by-request answers to Interrogatories
Nos. 1-14 within forty-eight hours;
b. Order Defendant to serve complete, request-by-request responses to RFP Nos. 1-9
within forty-eight hours;
c. Order Defendant to serve complete, request-by-request responses to RFA Nos.
1-22 within forty-eight hours; and,
d. Grant such further relief as the Court deems just and proper.
Date: August 6, 2026
Respectfully submitted,
——————————————————————————————————————————————
PLAINTIFF'S MOTION TO COMPEL
- 3 -
——————————————————————————————————————————————
PLAINTIFF'S MOTION TO COMPEL
- 4 -
