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You send the original Motion to Compel Documents to the Court Clerk. You send a copy to the attorney handling the lawsuit for Chase. Then call up the Judge's Judicial Assistant and ask for a hearing date for this motion to be heard. Then send out a Notice of Hearing for the Motion to Compel documents after the allotted time frame to produce the documents has come and gone. Say in your state it's 30 days to produce the documents. Call the Judicial Assistant at day 34 to set down the formal hearing. At the hearing the Judge will then give Chase so many days (usually 10 days) to produce the documents. After the 10 days comes and goes then is when you file the Motion to Dismiss. At the time you file the Motion to Dismiss call up the Judicial Assistant and get a hearing date and then send out the Notice of Hearing on Motion to Dismiss. Original to the Court, copy to the Judge along with a copy of your Motion to Dismiss and a copy of notice of hearing and a copy of the Motion to Dismiss to Chase's attorney. Good luck.
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