what are the effect of good motion
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In this motion, the movant gives a background of the dispute and then lists the specific Document categories sought. There are a total of 24 document requests at issue. The movant dutifully lists each request and then quotes the objection made by the respondent. After each request and objection, the movant then includes a paragraph why the requested information is relevant and why the documents should be produced. Many of the objections and arguments are identical and thus writing the motion involves considerable copying and pasting.
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