Los Angeles California Discovery — Sample Letter to Opposing Counsel regarding Deposition and Subpoena Ducks Cecum Dear [Opposing Counsel's Name], I hope this letter finds you well. I am writing in regard to the ongoing discovery process in the [Case Name] matter, specifically regarding the upcoming deposition and subpoena duces tecum. In order to ensure a smooth and efficient discovery process, I kindly request your cooperation and adherence to the following guidelines. Deposition: The deposition of [Witness's Name] has been scheduled for [Date and Time] at [Location]. Pursuant to the California Code of Civil Procedure, you are entitled to conduct the deposition of this witness in accordance with the established procedures. It is essential that both parties demonstrate professionalism, respect, and adherence to the legal standards throughout the deposition process. To facilitate a productive deposition, I kindly request that you provide any specific topics or areas of questioning you intend to cover during the deposition. This will enable our team to adequately prepare the witness and ensure a focused and relevant deposition. Please note that any objections to questions during the deposition should be limited to those specifically authorized by law. We expect all objections to be made in a timely manner and in compliance with the California Code of Civil Procedure. Subpoena Ducks Cecum: In addition to the deposition, we will also be serving a subpoena duces tecum on [Third Party's Name] to produce relevant documents, records, or tangible items related to the case. As per the California Code of Civil Procedure, the subpoena duces tecum must: 1. Clearly specify the items or categories of items to be produced. 2. Set a reasonable time and place for the production of these items. 3. State the date, time, and location where the production should take place. To ensure a smooth process, we kindly request your cooperation in providing a copy of the subpoena duces tecum to your client. This will allow them to assert any objections or raise any concerns regarding the documents or items requested within a reasonable time frame. Additionally, please be advised that any objections made by your client should be supported by proper legal grounds. Alternative Types of Los Angeles California Discovery — Sample Letters: 1. Sample Letter to Opposing Counsel regarding Interrogatories: This letter provides a detailed description and guidelines for responding to written interrogatories in the Los Angeles discovery process. 2. Sample Letter to Opposing Counsel regarding Request for Admission: This letter outlines the proper procedure and expectations for responding to requests for admissions in the Los Angeles discovery process. 3. Sample Letter to Opposing Counsel regarding Request for Production of Documents: This letter describes the necessary steps and requirements for producing requested documents during the discovery process in Los Angeles. In conclusion, I believe that by adhering to the guidelines outlined above, we can facilitate a smooth and efficient discovery process. If you have any concerns or would like to discuss any aspect of the forthcoming deposition or subpoena duces tecum further, please do not hesitate to contact me. Thank you for your attention to this matter, and I look forward to your cooperation. Sincerely, [Your Name] [Your Law Firm] [Contact Information]