Filing Summary

This filing is UWS’s motion to force the NRA to properly respond to UWS’s discovery requests. It cites many of the reasons stated in its letter to the NRA attacking the NRA’s responses and objections to its discovery requests.

Key Points

• UWS argues that the NRA’s responses to its discovery requests were untimely and must therefore be struck. (Para. 2.)
• UWS argues that the NRA’s “objections and responses show a complete lack of respect and … most, if not all, objections were not made in good faith, were made to harass and cause unnecessary delay, and increase the cost of the litigation.” (Pg. 2.)
• UWS states that the NRA’s “failure to grasp the importance of the legal process and the rules of good faith within the discovery process is troubling, especially considering the animosity toward Plaintiff and contempt for the discovery process demonstrated by the NRA.” (Pgs. 5–6.)