Oatey

I.

BACKGROUND FACTS AND PROCEDURE

In April 2012, Plaintiff filed a complaint against Defendant, asserting one cause of

action for professional negligence. Plaintiff alleged that she retained Defendant, an

attorney, to provide professional services related to a surrogacy contract and the

procurement of a proper surrogate, but failed to use reasonable skill and care in providing

these services, causing Plaintiff damages in excess of $2.5 million.

A. Defendant's First Round of Discovery and the April 2013 Order Compelling Responses

In October 2012 Defendant served the following discovery requests on Plaintiff:

form interrogatories (set one), special interrogatories (set one) and request for production

of documents (set one). Having received no responses to the discovery requests (or to the

three meet and confer letters and one telephone call to Plaintiff's attorney), in December

2012 Defendant filed a motion to compel Plaintiff to respond without objections to these

discovery requests and for attorney fees and costs.

Plaintiff did not oppose the motion, and in April 2013 the court granted it,

ordering that Plaintiff provide verified responses without…