IN THE DISTRICT COURT OF THE UNITED STATES FOR THE

MIDDLE DISTRICT OF ALABAMA, EASTERN DIVISION,

B. B. a minor, by and )

through his mother and next friend, )

OWENA KNOWLES, )

)

Plaintiff, )

)

v. ) Civil Action No.: 3:06cv715-MHT

)

PAWN CITY, INC.; INTERSTATE )

ARMS CORPORATION; NORINCO )

a/k/a CHINA NORTH INDUSTRIES )

CORPORATION, QIQIHAR HAWK )

INDUSTRIES, et al., )

)

Defendants. )

PLAINTIFF'S MOTION TO COMPEL DEFENDANT NORINCO'S 

DISCOVERY RESPONSES WITHIN FOURTEEN (14) DAYS

COMES NOW the plaintiff and moves this Court to order Defendant 

Norinco to answer plaintiff's First Interrogatories and Request for Production. 

As grounds therefore, plaintiff states as follows:

1. Plaintiff served Defendant Norinco with interrogatories and requests for

production on or about November 27, 2006 (Exhibit A). Defendant 

Norinco's responses to plaintiff's discovery were due on December 27, 

2006.

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2. Counsel for plaintiff and counsel for defendant Norinco have had 

discussions and corresponded numerous times regarding the past due 

discovery.

3. To date, plaintiff has not received responses to first interrogatories and 

request for production propounded on November 27, 2006.

4. The Honorable Court has denied plaintiff's Motion To Extend 

Scheduling Order, and the plaintiff is in need of Defendant Norinco's 

responses to discovery previously propounded, in order to properly 

conduct further discovery.

WHEREFORE, premises considered, the plaintiff respectfully requests 

this Court to enter an Order compelling defendant Norinco to answer 

plaintiff's outstanding discovery within fourteen (14) days.

Respectfully submitted,

/s/ David J. Hodge 

DAVID J. HODGE

Of Counsel for Plaintiff

OF COUNSEL:

PITTMAN, DUTTON, KIRBY & HELLUMS, P.C.

2001 Park Place North

1100 Park Place Tower

Birmingham, Alabama 35203

(205) 322-8880

(205) 328-2711 facsimile

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Nick Wooten, Esq.

WOOTEN & CARLTON, P.C.

P.O. Drawer 290

Lafayette, Alabama 36862

CERTIFICATE OF SERVICE

I hereby certify that on the 20th day of February, 2007, I electronically 

filed the foregoing with the Clerk of the Court using the CM/ECF system

which will send notification of such filing to the following: All counsel of 

record. 

I hereby further certify that I have mailed by United States Postal 

Service the document to the following non-CM/ECF participants:

Qiqihar Hawk Industries

No. 3 Delong Road

Technique Industrial Development District

Heilong Jiang Proy Province

Peoples Republic of China

/s/David J. Hodge _____ 

Of Counsel for Plaintiff

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