legal writing drafting a motion to compel

Assume that your firm, Stahl & Beetum, PC , 13 Sol St., Wigmore, IL 00001, served the interrogatories and Notice to Produce on Plaintiff’s attorney. The Wigmore Supreme Court Rule 213 Written Interrogatories to Parties subsection (d) requires the opposing party to answer the interrogatories within 28 days of receipt. The Wigmore Supreme Court Rule 214 Discovery of Documents subsection (a) requires that the opposing party tender the requested documents within 28 days of receipt of the Notice to Produce. The Wigmore Supreme Court Rules are provided here.

Your supervising attorney, B. G. Brothers tells you that she served Interrogatories and a Notice to Produce on Plaintiff’s counsel over 120 days ago. She further tells you that she has had two personal conferences with Plaintiff’s counsel, Rich N. Moore, requesting that he immediately provide his client’s responses to both discovery requests. In both conferences Mr. Moore promised to serve his client’s responses to both discovery requests within two weeks, but he has not done so. Brothers tells you she is tired of waiting and getting empty promises from Plaintiff’s counsel. She asks you to draft a Motion to Compel Plaintiff’s Answers to Written Discovery. She tells you to review the applicable Wigmore Supreme Court Rules on discovery and then hands you a document with the applicable rules. It is attached here.

Ms. Brothers tells you to read and include in your motion citation to and a discussion of case law. She says you may use Transamerica Ins. Group v. Lee, 164 Ill. App. 3d 945, 518 N.E.2d 413 (1987), Mueller v. Insurance Ben. Admrs., Inc., 175 Ill. App. 3d 587, 529 N.E.2d 1126 (1988), or such other case you may believe appropriate. She says the Motion is due by Sunday at 1159pm. She also gives you a form for a Motion to Compel that she has from her prior firm which was a Plaintiff’s firm.

 
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health care accreditation 400 words

  • Research the role of regulation and accreditation, and discuss the role that each plays in holding health care professionals and organizations accountable.
  • Choose 2 of the following types of health care organizations:
    • Acute care hospital
    • Nursing home
    • Home health care
    • Ambulatory care
  • Discuss accreditation as it relates to those organizations.
  • Describe the role that accrediting agencies have in clinical quality improvement and improving health care outcomes.

Note: Use APA style to cite at least 2 scholarly sources from the last 5 years. 400 word

 
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discussion 5 33

Symbolic interactionists point to symbols as having the power to shape attitudes and behaviors. Symbols possess the ability to shape norms and create new normative behavior. This is particularly relevant for how families originate. In your post, analyze a cross-cultural symbolic rite of same-sex or traditional marriage and a dating rite for its role in gender construction within the United States and compare it to an example from another culture.

 
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customer profile

Introduction:

Consider the following scenario as you approach this assignment:

You work at a marketing firm and have been asked to create a customer profile for one of the clients listed. Your first task is to create a customer profile survey based on this example. The questions in your survey will help you identify and describe the typical customer. At your client’s store location, conduct interviews of customers using the survey you developed. You then will use the data collected from your survey to create a customer profile PowerPoint presentation that you will submit to your client.

Instructions:

Applying what you have learned from the course readings and instructional materials, complete the following:

  1. Choose a client store from the list to conduct your customer profile survey and interview.
  2. Create a customer profile survey.
  3. Interview 5-10 customers at the client store using the survey you developed. Alternatively, survey family or friends who are customers of the client store you chose. To get the highest level of diversity and variance of the population, you are strongly encouraged to conduct your survey in person at the client store.
  4. Using PowerPoint, create a customer profile with the data collected from your survey. Use graphs to represent the data. Your customer profile must include demographic, geographic, psychographic, and behavioral factors. In addition, include an outline of the Consumer Buying Process.

Client Stores:

Choose one of the following “client stores” and develop a profile for a typical customer:

  1. Walmart
  2. Safeway
  3. Whole Foods
  4. Star
  5. Target


 
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resume question

please read through the paper. please if there is anything about job please write something in Kuwait City because im from there. Im currently studying in America, but I would like to make my papers in Kuwait to make them about it. Please write in high school English because im not fantastic. write it in a very good high school language. Please read through the attachment clearly and if you want to mention a career or something like that mention the careers in Kuwait (if it needed) (I haven’t looked at the assignments yet). Im not sure how many pages.

 
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public administration 11

Assignment 3: Leadership and Ethics

Due Week 9 and worth 240 points

In this assignment, you will explore how ethical behaviors can impact the issue you selected in Assignment 1.

Write a four to five (4-5) page paper in which you:

  1. Propose two (2) ethical concerns that management may need to address related to the issue you selected in Assignment 1. Provide a rationale for your response.
  2. Analyze the overall manner in which organizational structure impacts organizational ethics. Select one (1) public agency or one (1) non-profit organization in which the ethical concerns related to the issue you selected may not be considered unethical. Provide a rationale for your response.
  3. Use the Inventory of Public Management Skills Management, located on pages 11 to 12 of the textbook, to construct a self-evaluation. Assess your level of development in each of the skills. Discuss two to three (2-3) activities that would affect your ability as a leader to address the ethical concerns discussed in Question 1.
  4. Based on the response in Question 3, discuss two to three (2-3) strategies you will implement to become an effective public administrator.
  5. Include at least four (4) peer-reviewed references (no more than five [5] years old) from material outside the textbook. Note: Appropriate peer-reviewed references include scholarly articles and governmental Websites Wikipedia, other wikis, and any other Websites ending in anything other than “.gov” do not qualify as academic resources.

Your assignment must follow these formatting requirements:

  • Be typed, double spaced, using Times New Roman font (size 12), with one-inch margins on all sides; citations and references must follow APA or school-specific format. Check with your professor for any additional instructions.
  • Include a cover page containing the title of the assignment, the student’s name, the professor’s name, the course title, and the date. The cover page and the reference page are not included in the required assignment page length.

The specific course learning outcomes associated with this assignment are:

  • Rearrange public administration, both the traditional and the new approaches, from structural, functional, and process perspectives, as well as the key goals of the public and private sector.
  • Predict the changing nature and responsibilities for managing public and nonprofit organizations.
  • Critique ethics in public service and its influence on the study of public administration as it relates to political choice.
  • Compose the concepts of public leadership and management essential to the study of public administration.
  • Use technology and information resources to research issues in public administration.
  • Write clearly and concisely about public administration using proper writing mechanics.
 
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operational implications of process improvement

According to the case study, a kaizen event revealed that variability in operations performance and outcomes was the root cause of a bottleneck in scheduling MRIs. Three solutions were provided, including:

  • Modify the master schedule.
  • Streamline the insurance authorization process.
  • Implement standardized work instructions.

To prepare for this Assignment:

Read the Pediatric Hospital in Tough Market Pegs Growth to Lean Process Improvement case study by Tonya Vinas, located in the Learning Resources. Review the key metrics and current state of the organization before the interventions were conducted.

The Assignment:

In a 6- to 7-page report to the board of directors (not including title page or references):

  1. Assess operations requirements and resources for Pediatric Hospital. Describe what is working and what is not working.
  2. Conduct a quantitative and qualitative benchmark literature review and scan of operations best practices (from the health care industry or outside the health care industry) and provide and evaluate an example of an initiative that a high-reliability health care organization has implemented, and indicate how Pediatric Hospital can implement that initiative.
  3. Evaluate Pediatric Hospital’s readiness for the transition of health care systems from a volume- to value-based delivery system. Using data provided in this case, provide relevant and practical recommendations to improve its readiness and how it might affect the implementation of the initiative.
  4. Analyze the operational implications of 2–3 current health care reforms and mandates that might affect the implementation of the initiative.
  5. Consider current and future trends and forces in operations management excellence and assess how these can help this Pediatric Hospital and other similar health care organizations to become a sustainable model for high-reliability organization.

Additional References:

https://www.nist.gov/baldrige

https://www.nist.gov/baldrige/self-assessing/baldr…

 
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comparison shopping worksheet

Comparison Shopping

Background

Choose a product or service that you would like to purchase for your office or yourself: ______________

Search the internet to find three providers who have different prices for the product or service:

a.

b.

c.

Product Description

  1. Describe in 2 to 4 sentences the product or service you wish to purchase.
  1. Indicate the amount of money in dollars that you have budgeted to pay

for the product or service: $_________________

Product Comparison

  1. Complete the chart below with information from your research.

Name of Provider

Link to Website

Price of Product

  1. Compare in a total of 260 words the product or service offered on each website.

Website

Method of Delivery

Warranties

Tax Rates

Extra Components/Services

Other Differences

a.

b.

c.

Calculations

  1. Suppose each of these products/services has a 30% markup based on selling price.

Calculate each supplier’s cost for the product/service. [Hint: First find the markup in dollars, then use the formula Price=Cost + Markup to find the supplier’s cost.]

Website a: (name)

Website b: (name)

Website c: (name)

Supplier’s Cost:

$

$

$

  1. Now that you have calculated the cost of the product, use that information to calculate the percentage markup based on cost.[Hint: Percentage markup based on cost is = (Price-Cost)/Cost.]

Website a: (name)

Website b: (name)

Website c: (name)

Percentage Markup:

%

%

%

  1. Calculate the percentage difference between the price you would like to pay and the price of the product/service.

Remember, this percentage will be positive if the price of the product or service is lower than the price you would like to pay. If the price is over-budget then there will be a negative number. If the price is under budget then there will be a positive number. [Hint: To calculate the percentage difference, you should use the formula: (Budget – Price)/Budget.]

Website a: (name)

Website b: (name)

Website c: (name)

Percentage Difference:

%

%

%

Analysis

  1. Write a 175- to 350-word analysis of which product you would select for purchase. Keep in mind that your purchase decision does not necessarily have to be the product with the lowest cost but you should support your decision with information from your analysis.

 
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discussion caffeine as a competitive inhibitor

Discussion (Caffeine as a Competitive Inhibitor)


During this last week’s lecture, we discussed how coffee keeps us awake by competing with adenosine for the adenosine receptor. Read the article and watch the videos above. The article discusses other reasons why individuals respond differently to caffeine, all of which involve biochemistry. Discuss your thoughts about this article, including your personal experiences with caffeine. Were you surprised by any of the factors discussed in this article? Do you disagree with any of these factors? Which of these factors do you believe explains your response to caffeine? Are there any other common food-related chemicals that we commonly consume that act as a competitive inhibitor of a normal biological process in our body?

You should contribute one (1) comment (at least 300 words) to this week’s discussion. In your post, you should provide a detailed explanation to support your views (include references, if needed). You may use the questions I asked above or discuss another aspect of the article and videos that caught your attention.

 
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help with question 120

My class discussion question needs to be answer with at least 150 words with example. I would like for it to be in your own words. If not please cite in text with reference, No plagiarism please. Doesn’t need a title page.

Class: What traits serve a leader well? What traits do not? Explain your answer.

 
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