Motion filed on behalf of Delphi Salaried Retirees
- Published: Thursday, 21 February 2013 13:04
The following Motion was filed in The United States District Court For The Eastern District Of Michigan Southern Division.
PLAINTIFFS’ RULE 37 MOTION TO ENFORCE THIS COURT’S ORDER GRANTING PLAINTIFFS’ SECOND MOTION TO COMPEL DISCOVERY FROM DEFENDANT PENSION BENEFIT GUARANTY CORPORATION
I. The PBGC Has Violated the Court’s March 9, 2012 Order by Refusing to Produce Documents Related to the Plan’s Benefits and Liabilities, and the PBGC’s Related Recoveries
II. The PBGC Has Violated the Court’s March 9, 2012 Order by Refusing to Produce Thousands of Unspecified Responsive Documents on the Basis of Boilerplate Privileges
III. The Court Should Award Plaintiffs Their Reasonable Expenses Incurred in Making this Motion Pursuant to Fed. R. Civ. P. 37(a), and, If the PBGC Continues to Disregard This Court’s Discovery Orders, the Court Should Make Appropriate Findings of Fact Against the PBGC Pursuant to Fed. R. Civ. P. 37(b)