Sirsi Corporation v. Craven-Pamlico-Carteret Regional Library System

Filing 23

MOTION to Compel Responses to its First Set of Requests for Production of Documents by Sirsi Corporation. (Numbers, Robert)

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF NORTH CAROLINA
EASTERN DIVISION
Civil Action No. 4:11-cv-00059-BO
Sirsi Corporation d/b/a SirsiDynix,
Plaintiff,
SirsiDynix’s Motion to Compel Responses to
its First Set of Requests for Production of
Documents

v.
Craven-Pamlico-Carteret Regional
Library System,
Defendant.

Plaintiff Sirsi Corporation d/b/a SirsiDynix (“SirsiDynix”) moves the court for an order
compelling Defendant Craven-Pamlico-Carteret Regional Library System (“CPC Regional”) to
respond in full to SirsiDynix’s First Set of Requests for Production of Documents, deeming any
objections CPC Regional may have had to the discovery requests to be waived, and awarding
SirsiDynix its attorneys fees in connection with this motion. The grounds in support of this
motion are set forth in the accompanying brief.
The undersigned certifies that he has attempted to confer with counsel for CPC Regional
in an attempt to obtain responses to SirsiDynix’s First Set of Requests for Production of
Documents without court action.
Dated: October 17, 2011.

WCSR 6997763v1

WOMBLE CARLYLE SANDRIDGE & RICE
A Limited Liability Partnership
By:
/s/ Robert T. Numbers II____________
ROBERT T. NUMBERS, II (State Bar No. 34134)
150 Fayetteville Street, Suite 2100
Post Office Box 831
Raleigh, North Carolina 27602
[phone]/[phone] (facsimile)
Attorney for Plaintiff

CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing was filed electronically with the Clerk of
Court using the CM/ECF system, which will send notification of such filing to the following:
Lee W. Bettis , Jr.
The Bettis Law Firm
P. O. Box 848
New Bern, NC 28560
Email: [e-mail]
Attorney for Defendant

Dated: October 17, 2011.

WOMBLE CARLYLE SANDRIDGE & RICE
A Limited Liability Partnership
By:

/s/ Robert T. Numbers II____________
ROBERT T. NUMBERS, II (State Bar No. 34134)
150 Fayetteville Street, Suite 2100
Post Office Box 831
Raleigh, North Carolina 27602
[phone]
[phone] (facsimile)
Attorney for Plaintiff

2
WCSR 6997763v1