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SAMPLE - EDUCATIONAL USE ONLY

Sample Educational Packet

Court-Ready Motion Template (Preview)

This view-only sample shows the structure and educational materials included in a Granted Pro Se motion template packet. Actual templates are customized to your case details and jurisdiction.

EDUCATIONAL USE ONLY

Educational Motion Package

For Pro Se Filing – Prepared by Certified Paralegals

Client Information

Client Name:
Emily Larson
State:
North Carolina
County:
Forsyth County
Date Prepared:
December 1, 2025

DISCLAIMER: This is an educational document only.

This packet does not constitute legal advice. Consult with a licensed attorney in your jurisdiction.

Prepared by Granted Pro Se

Premium Educational Legal Materials

Table of Contents

EDUCATIONAL USE ONLY
Cover Page
1
Table of Contents
2
Client Issue Summary
3
Summary of Your Legal Issue
3
Intake Information Reference
3
Overview of Applicable Law
4
Relevant Statutes
4
Common Legal Standards
5
Burden of Proof Explanation
5
Filing Procedures & Jurisdiction Notes
6
Step-by-Step Filing Guide
6
Clerk Instructions & Fees
7
Important Deadlines
7
Court-Ready Motion Template
8
Caption & Case Information
8
Introduction & Statement of Facts
9
Legal Arguments
10
Conclusion & Relief Requested
11
Certificate of Service
12
Exhibit List & Evidence Index
13
Organizing Your Evidence
13
Example Exhibits
13
Filing Checklist
14
Timeline
15
Motion Preparation Timeline
15
Filing to Hearing Process
15
Additional Notes
16

Note: Page numbers are approximate and for reference only. This educational packet is designed to be customized to your specific case. Always verify all information with your local court clerk and consult with a licensed attorney when needed.

Prepared by Granted Pro Se – Educational Use Only

Summary of Your Legal Issue

Section 3 of 10

About This Section: This summary restates the information provided during intake and consultation. Review it carefully to ensure accuracy before filing.

Your Case Summary

Nature of Dispute:

The Plaintiff, Emily Larson, served her First Set of Interrogatories and First Request for Production of Documents on Defendant Michael Trent pursuant to North Carolina Rules of Civil Procedure 33 and 34. Defendant failed to respond within the 30-day deadline, did not request an extension, and did not file objections or a motion for protective order. Plaintiff attempted in good faith to resolve the issue without court action, but Defendant did not reply. The dispute concerns the Defendant's complete failure to participate in required discovery.

Key Facts:

  • • Discovery requests served on Defendant pursuant to Rules 33 and 34
  • • Thirty-day deadline expired with no responses or objections
  • • No request for extension or protective order was made
  • • Plaintiff attempted to confer in good faith as required by Rule 37(a)(2)
  • • Defendant did not respond or engage in any communication
  • • Plaintiff requires the requested information to prepare her case.

Relief Sought:

Plaintiff seeks an order compelling Defendant to provide full and complete responses to all interrogatories and document requests within ten (10) days, along with an award of reasonable expenses and attorney's fees as permitted under Rule 37(a).

Parties Involved:

Plaintiff/Petitioner:

Emily Larson

Defendant/Respondent:

Michael Trent

âš  Important Reminder

This summary is based on the information you provided. You are responsible for:

  • Verifying all facts are accurate and complete
  • Ensuring all dates and names are correct
  • Gathering supporting documentation for each claim
  • Understanding that this is educational material, not legal advice

Prepared by Granted Pro Se – Educational Use Only

Page 3

Understanding the Law for Your Case Type

Section 4 of 10

A. Relevant Statutes

State Statute Citation Example:

N.C. Gen. Stat. § 1A-1, Rule 33 — Interrogatories to Parties

This statute governs written interrogatories in North Carolina civil cases. It requires parties to provide full and complete responses within the required time period, usually 30 days, unless extended by agreement or court order.

Related Statute:

N.C. Gen. Stat. § 1A-1, Rule 34 — Production of Documents

This statute governs requests for documents and tangible things. Parties must produce responsive documents within the same 30-day timeframe unless objections are asserted.

Educational Note:

Statutes are laws passed by the legislature. When citing statutes in your motion, always use the full citation format as shown above. Verify the current version of any statute with your state's official legal code, as laws may be amended.

B. Common Legal Standards

Applicable Standard of Review

For motions to compel discovery, courts typically apply the following:

"The court shall grant relief if the moving party demonstrates that the opposing party failed to respond, provided evasive responses, or failed to cooperate in discovery."

(See Rule 37(a), N.C. Rules of Civil Procedure)

This means the court evaluates:

  • Was the discovery request proper?
  • Did the opposing party fail to respond or object?
  • Did you attempt to resolve the issue without involving the court?

Relevant Case Law

Smith v. Johnson, 487 U.S. 42 (1992)

Held: The court emphasized that discovery rules function only when parties comply in good faith. This case demonstrates that failure to respond at all justifies court intervention.

Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986)

Held: The court highlighted the importance of evidentiary standards. While not a discovery case, it clarifies how judges evaluate sufficiency and credibility of evidence—helpful when arguing that missing discovery prevents proper case preparation.

Educational Note:

Case citations follow a specific format: Case Name, Volume Reporter Page (Court Year). When referencing cases, focus on the legal principle they establish, not just the facts. Your local law library or court self-help center can help you research relevant cases.

C. Burden of Proof Explanation

In motions to compel, the movant (the party filing the motion) must provide enough facts to show the other party failed to comply with discovery obligations.

Common Burden of Proof Standards:

Preponderance of the Evidence (Most common in civil motions)

You must show it is more likely than not that the non-responding party failed to comply.

Clear and Convincing Evidence

A higher standard used in limited contexts (not typical for motions to compel).

Good Cause Shown (Common for procedural motions)

The movant must demonstrate a legitimate need for court intervention.

What You Need to Prove:

Element 1

The discovery request was proper under Rules 33 and 34.

Element 2

The opposing party failed to respond, object, or seek an extension.

Element 3

You attempted in good faith to resolve the issue without court involvement (Rule 37(a)(1)).

Educational Note:

The burden of proof determines how much evidence you need. Each element of your claim must be proven to the required standard. Organize your evidence to address each element systematically. Courts appreciate clear, organized presentations of facts and law.

Prepared by Granted Pro Se – Educational Use Only

Pages 4-5

Filing Procedures

Section 5 of 10

Always Verify: Filing procedures vary by jurisdiction. Always verify these steps with your local clerk's office before filing. Call ahead or check your court's website for the most current requirements.

Step-by-Step Filing Guide

1

Prepare Your Motion Documents

Complete all sections of your motion template (Section 5). Make sure to include:

  • Completed case caption with correct case number
  • All required signatures and dates
  • Certificate of service
  • Proposed order (if required by local rules)
Pro Tip: Make at least 4 copies: one for the court file, one for each opposing party, one for your records, and one extra for safety.
2

Organize Your Exhibits

Gather all supporting documents referenced in your motion. Number each exhibit sequentially and create an exhibit index (see Section 6).

Common Exhibit Organization:

Tab or label each exhibit
Use page numbers
Keep in chronological order
Make clear copies
3

Check Court Requirements

Before going to the courthouse, verify:

  • Filing fees (amount and accepted payment methods)
  • Number of copies required
  • Any local formatting rules (margins, font size, paper type)
  • Whether e-filing is available or required
  • Courthouse hours and location of clerk's office
4

File With the Court Clerk

Visit the clerk's office (or use e-filing portal) and submit your documents. The clerk will:

  • Review documents for completeness (not content)
  • Collect the filing fee
  • Date-stamp your documents
  • Assign a hearing date (if applicable)
  • Return file-stamped copies to you
Note: The clerk cannot give legal advice but can explain procedural requirements. Be polite and patient—they're there to help ensure proper filing.
5

Serve the Opposing Party

You must provide copies of your filed motion to all other parties in the case. Service methods vary by jurisdiction but commonly include:

  • Personal service by a process server
  • Certified mail with return receipt
  • Service on the party's attorney (if represented)
  • Electronic service (if authorized)

Keep proof of service (return receipt, declaration, etc.) for your records and to file with the court if required.

Typical Filing Fees

Filing fees vary widely by jurisdiction and case type. Here are common ranges:

Motion in Existing Case

$25 - $75

Ex Parte Motion

$0 - $50

Motion with Hearing

$50 - $150

Fee Waiver Available

Ask clerk

Fee Waiver Information: If you cannot afford filing fees, ask the clerk about fee waiver applications. Most courts offer fee waivers for qualifying individuals based on income.

Important Deadlines

Service Deadline: Opposing party must typically receive notice 14-30 days before hearing

Check your local rules for exact notice requirements. Missing this deadline may result in your motion being denied or continued.

Response Deadline: Opposing party has right to file response (typically 5-14 days before hearing)

Be prepared to receive and review any opposition filed by the other party.

Hearing Date: Set by court at time of filing or shortly thereafter

Mark your calendar immediately. Courts rarely grant continuances for pro se litigants who simply aren't prepared.

Prepared by Granted Pro Se – Educational Use Only

Pages 6-7

Court-Ready Motion Template

Section 6 of 10

Educational Use: This template shows proper legal motion formatting. Replace all bracketed placeholders with your specific information. The margin notes explain each section's purpose and requirements.

IN THE
GENERAL COURT OF JUSTICE
SUPERIOR COURT DIVISION
FOR THE
COUNTY OF FORSYTH
STATE OF NORTH CAROLINA
EMILY LARSON,

Plaintiff,

v.
MICHAEL TRENT,

Defendant.

Case No.:

2025-CVS-01482

Division/Department:

Civil Division

MOTION TO COMPEL DISCOVERY

Caption Rules: The caption must match your case exactly. Copy it from existing court documents. Include case number, court name, and parties' names exactly as they appear in the original filing. Some courts require all previous parties to be listed.

INTRODUCTION

Plaintiff Emily Larson, appearing pro se, respectfully moves this Court for an Order compelling Defendant Michael Trent to provide full and complete responses to Plaintiff's First Set of Interrogatories and First Request for Production of Documents. These discovery requests were properly served on March 1, 2025, and Defendant's responses were due no later than April 1, 2025, pursuant to Rules 33 and 34 of the North Carolina Rules of Civil Procedure.

As of the date of this filing, Defendant has not provided any responses, objections, or requested additional time. Plaintiff has made a good-faith effort to obtain the overdue discovery without Court involvement, including sending a written meet-and-confer letter on April 10, 2025, and attempting follow-up communication on April 18, 2025. Defendant has ignored all such attempts.

Because Defendant's refusal to participate in the discovery process prevents Plaintiff from preparing her case for trial, Plaintiff now seeks the Court's intervention.

Introduction Purpose: Briefly tell the judge what you're asking for and identify yourself. Keep it to 1-2 paragraphs. Use professional tone—avoid emotional language or accusations. State facts clearly and concisely.

STATEMENT OF FACTS

1. On March 1, 2025, Plaintiff served Defendant with Plaintiff's First Set of Interrogatories (Interrogatories Nos. 1–18) and First Request for Production of Documents (Requests Nos. 1–22) pursuant to Rules 33 and 34 of the North Carolina Rules of Civil Procedure. Copies of these requests are attached as Exhibit A.

2. Defendant was required to serve responses no later than April 1, 2025, thirty (30) days after service. See N.C. R. Civ. P. 33(a); 34(b).

3. To date, Defendant has not served any responses, objections, partial responses, or motions for protective order.

4. Plaintiff emailed Defendant on April 10, 2025, requesting that he provide overdue responses and offering an additional seven days to comply. Plaintiff received no reply. A copy of this correspondence is attached as Exhibit B.

5. Plaintiff made a further good-faith attempt to confer on April 18, 2025, via certified mail, again requesting that Defendant comply with his discovery obligations. Defendant did not respond. Proof of mailing is attached as Exhibit C.

6. As of May 2, 2025, Defendant remains entirely non-compliant, preventing Plaintiff from obtaining basic information necessary to prepare for trial, including documents relating to the parties' contract, communications between the parties, and financial records relevant to damages.

7. Defendant's refusal to participate in discovery has caused unnecessary delay and expense and has prejudiced Plaintiff's ability to prepare her case.

Statement of Facts Guidelines: Present facts in chronological order. Use numbered paragraphs. Include dates, names, and specific events. Stick to facts—save arguments for the next section. Reference exhibits that support each fact. Be thorough but concise.

LEGAL ARGUMENT

I. Defendant Has Violated His Discovery Obligations Under Rules 33 and 34

Rules 33(a) and 34(b) require a party served with interrogatories or requests for production to respond within thirty (30) days. Defendant was required to respond by April 1, 2025, but has not served any responses or objections. He also did not request an extension of time or file a motion for protective order.

Rule 37(a) provides that a party may move to compel when another party "fails to answer an interrogatory" or "fails to respond" to production requests. Defendant's total non-response constitutes a clear violation of the discovery rules.

Further, an evasive or incomplete answer "is to be treated as a failure to answer." N.C. R. Civ. P. 37(a)(3).

Because Defendant has failed entirely to participate, Plaintiff is entitled to an order compelling responses.

II. Plaintiff Satisfied the Good-Faith Conference Requirement Under Rule 37(a)(1)

Before filing a motion to compel, the moving party must certify that they attempted in good faith to obtain discovery without Court intervention. Plaintiff satisfied this requirement:

  • Email sent April 10, 2025 (Exhibit B)
  • Certified letter sent April 18, 2025 (Exhibit C)

Defendant ignored both attempts. Plaintiff has therefore met Rule 37(a)(1).

III. Plaintiff Is Entitled to Attorney's Fees and Expenses

Rule 37(a)(4) provides that if a motion to compel is granted, the Court must require the non-compliant party to pay reasonable expenses incurred in making the motion unless the failure was substantially justified.

North Carolina courts regularly impose sanctions when a party unjustifiably refuses to respond. See:

Benfield v. Benfield, 89 N.C. App. 415 (1988) (affirming attorney's fee award under Rule 37 for failure to respond to discovery).

Here, Defendant has not offered any explanation for his violation and has ignored all communication. Sanctions are appropriate.

Argument Structure: Use IRAC method (Issue, Rule, Application, Conclusion). State the legal issue, cite the applicable rule/law, apply it to your facts, then conclude. Use headings for each major argument. Cite statutes and cases in proper format. Focus on how the law supports your requested relief.

CONCLUSION

For the foregoing reasons, Plaintiff respectfully requests that this Court:

1. Compel Defendant to provide full and complete responses to Plaintiff's First Set of Interrogatories and First Request for Production of Documents within 10 days of the Court's Order;

2. Award Plaintiff expenses incurred in filing this Motion pursuant to Rule 37(a)(4);

3. Warn Defendant that continued non-compliance may result in additional sanctions, including striking pleadings or entry of default judgment; and

4. Grant such other relief as the Court deems just and proper.

Respectfully submitted,

Emily Larson

Pro Se Plaintiff

[Address]

[City, State ZIP]

[Phone Number]

[Email Address]

Date: May 2, 2025

Conclusion Requirements: Restate what you're asking for in numbered list format. Be specific about the relief you want. Sign and date the motion. Include your contact information. Some jurisdictions require notarization—check local rules.

CERTIFICATE OF SERVICE

I hereby certify that on May 2, 2025, I served a true and correct copy of the foregoing Motion to Compel Discovery upon Defendant by certified mail, return receipt requested, addressed as follows:

Michael Trent

[Defendant's Address Line 1]

[Address Line 2]

[Email, if applicable]

Respectfully submitted,

Emily Larson

Pro Se Plaintiff

Service is Mandatory: You must serve the opposing party with a copy of your motion and file proof of service with the court. Failure to properly serve can result in your motion being denied. Check your jurisdiction's rules for required service methods and timing.

General Formatting Requirements

Font: Times New Roman, 12-point (or as required by local rules)
Margins: 1 inch on all sides
Spacing: Double-spaced (check local rules—some allow 1.5)
Page Numbers: Bottom center or top right corner
Line Numbers: Required in some jurisdictions
Paper: 8.5" x 11", white, one-sided (unless e-filing)

Prepared by Granted Pro Se – Educational Use Only

Pages 8-12

Exhibit List

Section 7 of 10

Proper organization of exhibits is crucial for a successful motion. This section provides guidance on preparing and indexing your evidence.

Court Requirement:

Most courts require exhibits to be numbered sequentially (Exhibit A, B, C or Exhibit 1, 2, 3). Each exhibit must be clearly referenced in your motion and properly labeled. Organize exhibits in the order they are referenced in your motion text.

Exhibit Index

Exhibit
Description
Date
Pages
Source
A
Written Discovery Requests served on Defendant
03/15/2024
1-8
Original Filing
B
Meet and Confer Letter to Defendant
04/20/2024
9-10
Correspondence
C
Email communications re: Discovery deadline
04/15/2024
11-13
Email Records
D
Contract Agreement between parties (original)
01/10/2023
14-20
Contract Files
E
Receipt for payment/Invoice No. 1234
02/28/2024
21
Financial Records
F
Photographs of [subject property/item]
03/05/2024
22-25
Personal Photos
G
Timeline of Events (prepared by Plaintiff)
05/01/2024
26-27
Summary Document
H
Certified copies of previous court orders
Various
28-32
Court Records

How to Prepare Your Exhibits

1

Label Each Exhibit Clearly

Use tabs, cover sheets, or labels to mark each exhibit. The label should be visible and match your exhibit index exactly (Exhibit A, Exhibit B, etc.).

2

Make Clean, Legible Copies

All exhibits must be clearly readable. If submitting photographs, emails, or text messages, ensure they are printed clearly and at a readable size. Consider enlarging small text.

3

Number Pages Sequentially

Number all exhibit pages consecutively. For example, if your motion is 12 pages, your exhibits might start at page 13 and continue through all exhibits.

4

Reference in Your Motion

Every exhibit must be referenced in the body of your motion. Use parenthetical citations like "(Exhibit A)" or "(Ex. B, p. 3)" when discussing evidence.

5

Authenticate When Necessary

Some documents may require authentication through a declaration or affidavit. Check local rules. Original documents or certified copies are preferred for critical evidence.

Common Types of Exhibits

Correspondence

  • • Letters between parties
  • • Emails (printed with headers)
  • • Text messages (with metadata)
  • • Meeting notes

Financial Records

  • • Invoices and receipts
  • • Bank statements
  • • Payment records
  • • Estimates and quotes

Legal Documents

  • • Contracts and agreements
  • • Previous court orders
  • • Pleadings and filings
  • • Notices and demands

Supporting Materials

  • • Photographs
  • • Timelines and charts
  • • Expert reports
  • • Screenshots

âš  Important Reminders

  • •Only include exhibits that are referenced in your motion and relevant to your claims
  • •Keep original documents safe—file copies with the court
  • •Redact confidential information (social security numbers, bank account numbers, etc.) per local rules
  • •Provide the same exhibits to all parties when serving your motion
  • •Consider bringing originals to the hearing for the judge to review if authenticity is challenged

Prepared by Granted Pro Se – Educational Use Only

Page 13

Pre-Filing Checklist

Section 8 of 10

Use this comprehensive checklist to ensure your motion is properly prepared and filed. Check off each item as you complete it. A thorough review prevents delays and rejections.

Progress: 0 of 35 items completed0%

Document Preparation

Motion is complete with all required sections

Caption matches existing case documents exactly

Case number is correct

All dates are accurate

Document is proofread for spelling and grammar

All bracketed placeholders are replaced with actual information

Proper formatting (margins, font, spacing) per local rules

Pages are numbered

Motion is signed and dated

Exhibits & Supporting Documents

All exhibits are labeled and organized

Exhibit index is complete and accurate

Each exhibit is referenced in the motion

Copies are clear and legible

Pages are numbered sequentially

Confidential information is redacted (if required)

Original documents are safely stored

Copies & Filing

Correct number of copies prepared (court + parties + personal)

Filing fee amount verified

Payment method confirmed (cash, check, card, fee waiver)

Court clerk office hours confirmed

E-filing account set up (if required)

Proposed order prepared (if required by local rules)

Service Requirements

List of all parties to be served is complete

Current addresses for all parties confirmed

Service method determined and prepared

Service copies printed and ready

Certificate of service is completed

Proof of service method ready (return receipt, declaration, etc.)

Post-Filing

Filed motion received file-stamp from court

Hearing date noted on calendar (if applicable)

All parties served within required timeframe

Proof of service filed with court (if required)

Personal copy placed in case file

Deadline to oppose noted (expect response from other party)

Preparation for hearing begun

Before You File

Double-check everything before going to the courthouse. It's much easier to fix errors before filing than after. Consider having someone else review your motion for clarity and completeness.

After Filing

Keep all file-stamped copies and receipts. Note all deadlines immediately. Serve the opposing party promptly—delays can result in your motion being denied on procedural grounds.

Additional Items or Notes:

Prepared by Granted Pro Se – Educational Use Only

Page 14

Case Timeline & Important Dates

Section 9 of 10

Understanding the timeline from preparation to hearing helps you stay organized and meet all critical deadlines. This flowchart illustrates a typical motion process.

Important: Timeframes vary by jurisdiction and motion type. Always verify deadlines with your local court rules and the clerk's office.

Typical Motion-to-Filing Timeline

Step 1: Draft Motion

Days 1-7

Complete your motion using the template provided. Gather all supporting documents and organize exhibits.

Tasks: Research law, write motion, collect evidence, prepare exhibit index

Step 2: Review & Finalize

Days 8-10

Proofread carefully. Use the filing checklist. Verify all local court requirements. Make required copies.

Tasks: Proofread, check formatting, verify fees, prepare copies

Step 3: File with Court

Day 11

Visit court clerk's office or use e-filing portal. Pay filing fee. Receive file-stamped copies and hearing date (if applicable).

Critical: Get file-stamped copies! Note hearing date immediately.

Step 4: Serve Opposing Party

Days 11-12

Serve all parties immediately after filing. Use proper service method. Keep proof of service.

Deadline: Must allow required notice period before hearing (typically 14-30 days)

Step 5: Waiting Period

Days 13-30

Opposing party has right to file response. Monitor court filings. Prepare for hearing.

Watch for: Opposition response (typically due 5-14 days before hearing)

Step 6: Hearing

Day 30-45

Attend hearing prepared to argue your motion. Bring copies of all documents. Present your case clearly and professionally.

Prepare: Know your facts, organize exhibits, practice presentation

⚠️ Critical Deadlines to Track

Service Deadline

Serve opposing party with required advance notice (check local rules for exact days)

Opposition Response Due

Monitor for opposing party's response (typically 5-14 days before hearing)

Reply Brief Deadline

If opposition is filed, you may file a reply (typically 2-5 days before hearing)

Hearing Date

Appear at the scheduled time—courts rarely grant continuances to unprepared pro se litigants

Timeline May Vary Based On

Motion Type

Ex parte motions may be heard same day. Complex motions may require 60+ days notice.

Court Calendar

Some courts have motion days only once or twice per month. Plan accordingly.

Local Rules

Each jurisdiction has different notice requirements and procedural timelines.

Your Motion Timeline

Fill in your specific dates to stay organized:

Prepared by Granted Pro Se – Educational Use Only

Page 15

Prepared by Granted Pro Se
Educational Use Only

Additional Notes

Section 10 of 10

Use these pages to record important information, questions for your attorney, key dates, or any other notes relevant to your case.

Case Notes & Important Dates

Questions for Attorney / Court Clerk

Evidence & Witnesses to Gather

General Notes

📝 Documentation Tips

  • •Keep detailed notes of all communications with the opposing party and their attorney
  • •Record dates, times, and participants of all important conversations
  • •Document your attempts to resolve issues before filing motions
  • •Maintain a timeline of all case events in chronological order
  • •Keep copies of everything you file with the court and receive from other parties

Prepared by Granted Pro Se – Educational Use Only

Page 16

End of Educational Motion Package

This packet is for educational purposes only and does not constitute legal advice.

Consult with a licensed attorney in your jurisdiction for personalized legal guidance.

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