Motion,Ex Parte: JOSEPH E. CAMPBELL VS DEBRA L. CAMPBELL (E-CASE)

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                                IN THE CIRCUIT COURT OF KNOX COUNTY
                                       AT EDINA, MISSOURI


In Re: The Marriage of

JOSEPH E. CAMPBELL and
DEBRA L. CAMPBELL
                                                            Case No, 20KN-CC00031
JOSEPH E. CAMPBELL,                Petitioner,
DEBRA L. CAMPBELL,                 Respondent.      )

                                          MOTION TO COMPEL

        COMES        NOW      the Petitioner, Joseph E. Campbell, by his attorney, and for his motion,

states as follows:

         1       That Respondent filed a “Motion to Hold Petitioner in Contempt on November 14,

2022, and that an Order to Show Cause was entered on November 16, 2021, ordering the Petitioner

to appcar in Court on December 27, 2021, said Order to Show                 Cause being served upon the

Petitioner on November 29, 2021.

        2.       That in response thereto the Petitioner retained counsel, who            filed a Motion for

Continuance on December 9, 2021, requesting a continuance of the hearing scheduled December

27, 2021, and that counsel for Respondent            filed a response thereto stating Respondent     had no

objection to the Court granting Petitioner’s Motion for Continuance.

        3        That   in conjunction      with the    filing of Petitioner’s   Motion    for Continuance,

Petitioner’s First Interrogatories were served upon Respondent’s attorney of record on December 9,

2021.

        4        That   on    January   5, 2023,   Respondent   file a Motion    for Extension   of Time.   to

Respond to Petitioner’s First Interrogatories to Respondent.
5        That    said     Motion   for   Extension   of Time     to   Respond   to   Petitioner’s   First

Interrogatories to Respondent has never been noticed for hearing and that Respondent has neither

answered nor objected to said interrogatories and that the time for doing so has long since expired.

        6        That Petitioner desires to have this matter concluded, but cannot proceed without full

answers to Petitioner’s First Interrogatories to Respondent,

        WHEREFORE,              Petitioner prays for an order of this Court compelling Respondent to fully

and completely answer Petitioner’s First Interrogatories to Respondent by a date certain to be set by

the Court, and that in default thereof, that sanctions be imposed upon the Respondent, and for such

other and further relief as the Court shall deem meet and just in the premises.




                                                     Respectfully submitted,

               PROOF OF SERVICE
 THE UNDERSIGNED CERTIFIES THAT A TRUE COPY
 OF THIS INSTRUM      WAS SERVED UPON THE
                                                     By.                 A.
 ATTORNEY(S) O!    CORD OF       PARTY(S) ‘TO
 THE ABOVE STYLI     CAUSE VIA THE COURT'S             AMY L.     HNEMUS, #60191
 ELECTRONIC SY:      TO SAID ATTORNEY(S) AT
 1    BUSINESS ADDRESS AS DISCLOSED IN THE             WASINGER PARHAM, L.C,
 PLEADINGS OF RECORD HEREIN ON THIS 26" DAY            P.O. Box 962
 OF JANUARY, 2024.
                                                       Hannibal, Missouri 63401
                                                       (573), 221-3225
               TAMES D TERRELL                         fax: (573) 221-1991
                                                       alohnemus@wasingerla com
                                                       ATTORNEY FOR PETITIONER