evidance

In my case the Plaintiff has entered into evedence a screen shot of the account and it shows a zero balance ....... there was no bill of sale nor forward flow agreement attached to the case. plus Plaintiff motioned for discovery and so I followed suit and submitted my own discovery questions plus my Answer to the complaint and my affirmation question were never answed by the plaintiff lawyers so I figure that I file a mostion to compel to dismiss and here is what I think woulf work based on Discovery Non-Compliance:

The plaintiff has failed to respond to my discovery interrogatories and affirmative defense questions. This lack of response hinders my ability to adequately prepare my defense and demonstrates a failure on the part of the plaintiff to engage in the discovery process as mandated by law. and violates procedural rules governing discovery, Michigan Court Rules (MCR), particularly MCR 2.301 through MCR 2.313. further supporting dismissal of the case.

The Defendant demands Sanctions for Non-Compliance, by Dismissing actions or rendering judgments by default against the non-compliant party with prejudice.

any thoughts would be a great help

Thanks And Semper Fi