Colorado Sample Letter for Plaintiff's Motion to Compel Answers to Plaintiff's Second Set of Interrogatories [Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] [Opposing Counsel's Name] [Opposing Counsel's Law Firm] [Law Firm's Address] [City, State, ZIP] Re: Plaintiff's Motion to Compel Answers to Plaintiff's Second Set of Interrogatories Dear [Opposing Counsel's Name], I hope this letter finds you well. I am writing to discuss the outstanding responses to the Plaintiff's Second Set of Interrogatories, as we have not received complete answers within the time frame governed by the Colorado Rules of Civil Procedure. As you are aware, the Plaintiff provided a Second Set of Interrogatories on [date], and the responses were due within [time frame] days of receipt, in accordance with Rule [Rule number] of the Colorado Rules of Civil Procedure. However, to date, we have not received the complete and proper responses from your client. It is important to note that the timely exchange of information and discovery is crucial for the fair and efficient resolution of this case. Failure to provide complete and detailed responses inhibits the parties' ability to prepare their respective cases and may lead to unnecessary delays and complications. We kindly request that you immediately provide the outstanding answers to the Plaintiff's Second Set of Interrogatories. Specifically, we specifically request answers to the following interrogatories: [Insert specific interrogatories that remain unanswered] Additionally, please ensure that the responses are thorough, complete, and comply with the relevant rules and regulations. Failure to provide complete and proper answers may compel the Plaintiff to seek remedies, such as filing a motion for sanctions or other appropriate relief, as allowed by the Colorado Rules of Civil Procedure. We expect your prompt cooperation in this matter. Please provide the aforementioned responses no later than [deadline, generally 14 days from the date of this letter]. Should you have any reasonable objections, please provide a detailed explanation and legal basis for each objection. If we do not receive the requested responses within the specified time frame, we will have no choice but to file a Motion to Compel with the court seeking an order compelling your client to provide the outstanding responses. Additionally, we also reserve the right to seek reasonable costs and attorney fees incurred due to your client's failure to comply. Thank you for your attention to this matter. We trust that you will promptly provide the requested information. If you have any questions or need further clarification, please do not hesitate to contact me. Sincerely, [Your Name] [Your Title/Role] [Your Law Firm] [Law Firm's Address] [City, State, ZIP] [Email Address] [Phone Number] Keywords: Colorado, Sample Letter, Plaintiff's Motion to Compel Answers, Second Set of Interrogatories, Colorado Rules of Civil Procedure, fair and efficient resolution, timely exchange of information, discovery, delays, complications, prompt cooperation, objections, legal basis, Motion to Compel, court order, reasonable costs, attorney fees, clarification.
Colorado Sample Letter for Plaintiff's Motion to Compel Answers to Plaintiff's Second Set of Interrogatories
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Read each question (interrogatory) very carefully. Answer only the question that is asked, and avoid the temptation to over-explain your answer. If the question contains several parts, you may break your answer into parts as well. It is also possible that you might object to the question.
A motion to compel further responses to interrogatories is a prime example. (This is where you've received responses to interrogatories, believe them to be incomplete, and you want the court to order the responding party to provide further responses.)
However, you can object to interrogatories that call for legal conclusions. You can also object to questions if they are not at all related to the court case. To object, you need to write out the reasons for the objection instead of answering the question.
Your answers to the interrogatories should usually be short, clear, and direct and should answer only the question that is being asked. This is not the time to set out your entire case or defense to the other side. Take the time to make sure your answers are correct and truthful.
If you are unable to answer a specific question because you don't know or don't have access to the appropriate information, you must indicate the reasons. You may refer to a previous response when responding to an interrogatory providing the previous response sufficiently answers the later interrogatory.
(b) Good Faith Efforts to Confer Before a party files a motion to compel a response to discovery, the party must make a good faith effort to confer with the person or party allegedly failing to properly respond to a request for discovery in an effort to secure information or material without action by the ALJ.
(a) The party to whom interrogatories have been propounded shall respond in writing under oath separately to each interrogatory by any of the following: (1) An answer containing the information sought to be discovered. (2) An exercise of the party's option to produce writings.
There is no form for your answer, but you typically have to respond in a specified format, using paper with numbers down the left-hand side, with your name and address at the top left, the name of the court and of the case, and the case number.
