Elevate your litigation strategy with our free, powerful Motion to Strike Template - a must-have for personal injury attorneys. A Motion to Strike can remove pleas, statements, and evidence from judicial proceedings in a lawsuit.A motion making any of these defenses shall be made before or at the time of pleading if a further pleading is permitted. Pleadings in civil litigation are formal written documents that outline the claims, defenses, and legal arguments of the parties involved in a lawsuit. If you have any questions or need additional support, don't hesitate to reach out to our experienced team at Georgia Trial Attorneys. A motion in opposition would be sufficient. Try filing a motion for sanction too (based on refusal to follow orders and requests). DATED: November 6, 2002. The ESI shall be provided in the following format (i.e. , Meta-Data, Native File, Static Image or other searchable or non-searchable format) .