IN THE CIRCUIT COURT FOR ANNE ARUNDEL COUNTY, MARYLAND MICHAEL G, LENETT Plaintiff,

v.
VIRGINIA R. RAMSEY, ET AL. Defendants.

Case No.: 02C11163878

PLAINTIFF'S MOTION TO STRIKE COMES NOW, the Plaintiff, Michael G. Lenett, by undersigned counsel, and moves this Honorable Court to strike Defendant Ramsey's Answer and approximately 200 pages of exhibits and discovery that Defendant Ramsey improperly appended to her Answer, and for cause states as follows: 1. On September 6, 2011, Plaintiff filed a complaint against Defendant Ramsey and others, asserting claims for defamation and false light arising from, among other things, defamatory statements that Defendant Ramsey published that personally attacked Plaintiff. 2. On October 24,2011, Defendant Ramsey filed an Answer to the complaint. With her Answer, Defendant Ramsey filed approximately 200 pages of documents, which included unsigned answers to interrogatories and other documents. Ms. Ramsey's Answer references and relies on these documents. 3. The Maryland Rules do not permit Defendant Ramsey to file these documents with her Answer. First, with respect to the discovery, Md. Rule 2-401 (d)(2) provides that "discovery material shall not be filed with the court." (Emphasis added). Here, Defendant Ramsey clearly contravened this Rule when she filed unsigned interrogatory responses.

4. Second, Md. Rule 2-323 provides that "ft] he answer shall be staled in short and plain terms and shall contain the following: (1) the defenses permitted by Rule 2-322 (b) that have not been raised by motion, (2) answers to the averments of the claim for relief pursuant to section (c) or (d) of this Rule, and (3) the defenses enumerated in sections (f) and (g) of this Rule." Md. Rule 2-323 does not authorize a party to file exhibits with an answer. 5. Md. Rule 2-322 provides that "the court may order any insufficient defense or any improper, immaterial, impertinent, or scandalous matter stricken from any pleading or may order any pleading that is late or otherwise not in compliance with these rules stricken in its entirety." 6. Because Defendant Ramsey filed impertinent and improper material and relied on this impertinent and improper material in her Answer, the appropriate remedy is for this court to strike the Answer, the attached documents, and unsigned interrogatories from the record. 7. Pursuant to Md. Rule 2-322, the Answer, attached documents, and unsigned interrogatory responses that Defendant Ramsey filed should be stricken. Moreover, the Maryland Rules expressly prohibit a party from filing discovery responses such as the unsigned interrogatories that Defendant Ramsey filed in this case. Accordingly, Plaintiff respectfully requests that this Court strike this improper and impertinent material. WHEREFORE, Plaintiff respectfully requests that this Court strike the impertinent and improper material that Defendant Ramsey filed in this matter including (1) her Answer, (2) the attached documents, and (3) unsigned discovery. Alternatively, Plaintiff requests that all documents except for the Answer be stricken from the record.