Subject: District of Columbia Sample Letter for Plaintiff's Motion to Compel Production of Requested Documents [Your Name] [Your Address] [City, State, Zip Code] [Email Address] [Phone Number] [Date] [Opposing Party's Attorney's Name] [Opposing Party's Attorney's Address] [City, State, Zip Code] Re: Case No. [Case Number] Plaintiff's Motion to Compel Production of Documents Requested in Second Request for Production of Documents Dear [Opposing Party's Attorney's Name], I hope this letter finds you well. I am writing on behalf of the Plaintiff in the above-mentioned case, to notify you of a Motion to Compel the Production of Documents. Despite previous requests for production, it has come to our attention that the requested documents have not been provided or adequately addressed. This motion seeks to rectify the situation and ensure compliance with the rules of discovery. [Keywords: District of Columbia, sample letter, Plaintiff's Motion to Compel] As you are aware, in accordance with the civil practice rules of the District of Columbia, specifically Rule XX of the Superior Court Rules of Civil Procedure, all parties involved in litigation have a duty to produce relevant and non-privileged documents as requested during the discovery process. It has become evident that the production of documents outlined in Plaintiff's Second Request for Production of Documents, dated [date], has not been satisfactorily addressed. This lack of cooperation impedes the resolution of this case and violates our client's rights to a fair and timely discovery process. [Keywords: District of Columbia, sample letter, Plaintiff's Second Request for Production of Documents, Motion to Compel] The specific documents sought in Plaintiff's Second Request for Production of Documents are crucial to the determination of key issues in this case. The requested documents include but are not limited to: 1. [Document description] [Keywords: District of Columbia, Plaintiff's Second Request for Production of Documents, document description] 2. [Document description] [Keywords: District of Columbia, Plaintiff's Second Request for Production of Documents, document description] 3. [Document description] [Keywords: District of Columbia, Plaintiff's Second Request for Production of Documents, document description] [Add any additional document descriptions here] [Keywords: District of Columbia, Plaintiff's Second Request for Production of Documents, document description] Given the importance of the above-listed documents and their relevance to the facts in dispute, we kindly request that you promptly produce these items within [number of days as specified by court rules] days of receiving this letter. In the event that you believe the requested documents are protected by privilege or that certain documents are not within the scope of discovery, we respectfully request that you provide a detailed privilege log or a written explanation outlining your objections as required by the District of Columbia rules of civil procedure. [Keywords: District of Columbia, sample letter, Plaintiff's Motion to Compel, objections] Failing to comply with our request or provide an adequate explanation for your objections within the specified time frame may force us to seek intervention from the court. We believe it is in the best interest of both parties to resolve this matter amicably and avoid unnecessary judicial involvement. We trust that you will promptly take the appropriate steps to ensure compliance with the discovery obligations. Furthermore, we kindly request your written response to this motion within [number of days] days of receiving this letter. Thank you for your attention to this matter. Should you have any questions or require further clarification, please do not hesitate to contact me at [phone number] or [email address]. Sincerely, [Your Name] [Your Law Firm's Name, if applicable] [Your Law Firm's Address, if applicable] [City, State, Zip Code]
District of Columbia Sample Letter for Plaintiff's Motion to Compel the Production of the Documents Requested in Plaintiff's Second Request for Production of Documents
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Common objections to requests for production or inspection include: The request is overly broad or unduly burdensome. ... The request is vague, ambiguous, or unintelligible. ... The request is not reasonably calculated to lead to the discovery of relevant, admissible evidence.
The following (if applicable) are some grounds for objecting to a request for admission: ? The request is vague or overbroad. ? Attorney-client privilege. ? The request is not relevant to this case.
Grounds For Motion ? A party may move to compel the production of documents or things if the response (1) agrees to comply, but compliance is incomplete, (2) the responding party's indication of inability to comply is incomplete, inadequate, or evasive, or (3) an objection to a request is made that is too general or ...
I am producing all of the requested documents that exist. I am producing all of the requested documents in my possession. I have requested copies of additional documents and expect to produce them by ___________________________ (date).
You can write back to the person making the request and explain why you are objecting. You must have a valid reason to object to giving the other party the documents.
Generally, a request for production asks the responding party to make available the original documents, but a requesting party may permit photocopies of the requested documents be sent instead, if inspection of the original document is not necessary.
How to Request Production of Documents and Things Download the template for Request for Production. ... Fill out basic information at the top. ... Choose a location for the other side to bring the documents. ... Add your own definitions (if useful) ... Write your requests for production. ... Sign and date the document. ... Make copies.
A Motion to Compel is a formal request to the Court to require a party or a non-party in a lawsuit to comply with a discovery request such as a request for production, request for admission, interrogatory, or subpoena.
