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NOTICE OF MOTION To: Abraham and Associates, LLC Attorneys for Defendant 1800 East Roosevelt Rd Glen Ellyn, IL 60137

Please take notice that on December 19, 2013, 10:30 p.m., I will appear before the Honorable Judge Roy Snyder, or such judge as may be sitting in his stead, in Courtroom 155, and then and there present Plaintiffs MOTION TO COMPEL DISCOVERY, a copy of which is attached hereto and served upon you.

Seymour Burns
Seymour Burns Attorney for Plaintiff CERTIFICATE OF SERVICE I certify that I served the foregoing Notice of Motion by depositing a copy thereof in the U.S. Post Office box located at 3400 Ridgewood Ave, Bensenville, IL, addressed to the above referenced person and address, first class postage pre-paid, on December 5, 2013, 5:00 p.m. __________________ Notary

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MOTION TO COMPEL DISCOVERY Plaintiff, Rosie Green, by and through her attorneys, Burns and Smith Law Office, P.C., moves pursuant to Supreme Court Rule 219 for entry of an order compelling Defendants to comply with discovery, and for such other sanctions as may be just, stating as reasons therefore as follows: 1. On October 16, 2013, Defendants, and each of them, were served with Interrogatories pursuant to Rule 213 of the Illinois Supreme Court. Responses were due by rule on or before November 14, 2013. 2. On October 16, 2013, Defendants, and each of the, were also served with Request for Production of Documents in accordance with Rule 214. Responses were due by rule on or before November 14, 2013. 3. Attorneys for the Plaintiff have not received Defendants Answers to Interrogatories. 4. Defendants have failed and refused to provide documents in accordance with Request for Production of Documents. 5. In an attempt to resolve the matters in issue in accordance with Supreme Court Rule 201(k), Plaintiffs attorney telephoned Defendants attorney on November 15, 2013, and November 18, 2013, and left a voicemail message on both occasions. Defendants attorney did not return the calls. Attached hereto and made a part hereof is Plaintiffs attorneys confirmation correspondence as Exhibit A.

6. Plaintiff has been unable to prepare her case and has been prejudiced in her right to compensation due to Defendants failure to comply with discovery. Wherefore Plaintiff moves for entry of an order compelling Defendants compliance, and for such other sanctions as the Court deems just, including costs and reasonable attorney fees.

Seymour Burns
Seymour Burns Attorney for Plaintiff Burns and Smith Law Office, P.C. 3500 Ridgewood Ave Bensenville, IL 60106 ARDC #: 987654 (630) 555-0123

Burns and Smith Law Office, P.C. 3500 Ridgewood Ave Bensenville, IL 60106 attorney@burnssmithlaw.com
November 18, 2013 Mr. George Simpson Abraham and Associates, LLC 1800 East Roosevelt Rd Glen Ellyn, IL 60137 Re: Rosie Green vs. Iam Speedy, et al. Dear Mr. Simpson: I have attempted to contact you two times on the morning of November 15 and this afternoon in order to discuss with you your clients lack of compliance with our discovery requests, including Interrogatories and Request for Production. In both instances, I have been unsuccessful in reaching you. I am willing to give your client until November 30 to comply with my discovery requests. Please be advised that if I do not have your clients Answers, and he continues to refuse to provide documents required under my Request for Production by that date, I will seek assistance from the Court. Sincerely,

Seymour Burns Attorney at Law SB/sj

EXHIBIT A