Filed by Conrad · Case 26-104594-DO
35 Motion Discovery Sanctions 2026-05-18
Canonical record: rockenhaus.net. Disputed domains are indexed at /disputed-domains/ (not authoritative).
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STATE OF MICHIGAN
IN THE THIRD JUDICIAL CIRCUIT FOR THE COUNTY OF WAYNE
FAMILY DIVISION, DOMESTIC RELATIONS
ADRIENNE MARJORIE ROCKENHAUS, Case No. 26-104594-DO
Plaintiff/Counter-Defendant,
Hon. Nicole N. Goodson
v.
CONRAD ALAN ROCKENHAUS,
Defendant/Counter-Plaintiff.
DEFENDANT/COUNTER-PLAINTIFF'S MOTION TO DETERMINE SUFFICIENCY OF
ANSWERS TO REQUESTS FOR ADMISSIONS, TO COMPEL RESPONSES TO
INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS, AND
FOR DISCOVERY SANCTIONS
NOW COMES Defendant/Counter-Plaintiff Conrad Alan Rockenhaus, appearing pro se, and respectfully
moves this Court pursuant to MCR 2.312(B), MCR 2.313(A), and MCR 2.313(B) for (1) an order determining
that Plaintiff/Counter-Defendant's Answers to Defendant's First Set of Requests for Admissions are
insufficient and that the matters are deemed admitted, (2) an order compelling responses to Defendant's
First Set of Interrogatories (Nos. 1 through 20) and Defendant's First Set of Requests for Production of
Documents, and (3) sanctions under MCR 2.313(B) up to and including entry of default judgment on
Defendant/Counter-Plaintiff's Counterclaim as a discovery sanction. In support, Defendant/Counter-Plaintiff
states as follows.
INTRODUCTION
This motion addresses three separate discovery failures by Plaintiff/Counter-Defendant, all arising from the
same single discovery package served by Defendant on April 16, 2026.
First, on May 13, 2026, Plaintiff/Counter-Defendant served Answers to Defendant's First Set of Requests
for Admissions in which every one of fifty-three responses is the verbatim identical canned formula, "Plaintiff
cannot truthfully admit nor deny for lack of information or knowledge. Plaintiff has made reasonable inquiry
and the information known or readily obtainable is insufficient at this time to enable Plaintiff to admit or deny
the request for admission." That formula appears as the entire substantive answer to requests concerning
Plaintiff's own visits to FCI Milan, her own letters and packages sent to Defendant, her own TRULINCS
messages, her own sworn declarations filed in federal court, her own published blog and social media
content, her own access to Defendant's financial accounts, her own tax filings, her own emails to
Defendant's federal appellate attorney (including emails with text quoted verbatim in the requests), her own
statements to the Redford Township Police Department, her own communications with Ann Helgren, her
own possession of Defendant's identification and personal property, and her own statements made in her
own Petition for Personal Protection Order. A party cannot, in good faith, claim ignorance of her own
conduct, her own filings, and her own statements. The Answers are insufficient as a matter of law under
MCR 2.312(B), and the matters should be deemed admitted under MCR 2.312(B)(3).
Second, thirty-two days have elapsed since the twenty-eight-day response deadline for Defendant's First
Set of Interrogatories. No Answers have been served. The interrogatories ask Plaintiff/Counter-Defendant to
identify financial accounts into which Defendant's VA Disability Compensation and SSDI benefits were
deposited, to identify her access to Defendant's va.gov account using his id.me credentials, to provide a
month-by-month accounting of the federally protected benefits she received as Defendant's purported
fiduciary, to identify the location of Defendant's personal property and identification, and to identify her
communications with Ann Helgren, the Redford Township Police Department, and federal authorities
concerning Defendant. These are core subjects of Defendant's Counterclaim. Plaintiff/Counter-Defendant's
silence on each is total.
Third, the same twenty-eight days have elapsed for De
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About this filing
35 Motion Discovery Sanctions 2026-05-18: filing by Conrad Alan Rockenhaus in Rockenhaus v. Rockenhaus (Divorce), Michigan Case No. 26-104594-DO, Wayne County Circuit Court. PDF and searchable text at rockenhaus.net (canonical court record). Disputed third-party domains: /disputed-domains/.
- File name
35_Motion_Discovery_Sanctions_2026-05-18.pdf- Filed date
- Case number
- 26-104594-DO
- Category
- Filed by Conrad
- Disputed domains
- View disputed domains (asserted controlled by Adrienne Rockenhaus; not authoritative).
- Related context
- FAQ, Joe Prich evidence, Rob Hein
- Canonical record
- rockenhaus.net