As pro se in federal court, after six months of discovery, and on the last day to file dispositive motions, the plaintiff (a large bank) filed a partial motion for summary judgment. We are two months from trial. I properly sent plaintiff 16 interrogatories back in June which was due in July. I tried in good faith to get the bank to answer them but the bank attorney kept promising to get them to me but delayed. The attorney finally responded but did not identify the bank representative who answered interrogatories nor was it signed under oath. I again for a month asked the bank attorney to identify the corporate representative who answered my interrogatories and have him/her sign them under oath. The bank attorney again kept promising to properly submit interrogatories but never did. On September 25, 2020, I filed a motion to compel plaintiff to answer my interrogatories and have the corporate representative sign them under oath and that I be allowed to depose the corporate representative. The bank still has not produced the interrogatories and has now moved for partial summary judgment. Is this possible sanction conduct and can summary judgment be granted on that claim if the bank never properly answered my interrogatories that relates to the claim they moved for summary judgment on and my motion to compel is still pending?

December 9th, 2024