Delaware Sample Letter for conveying Responses to Request for Production of Documents

• Category: Letters - Legal - Production
• State: Multi-State
• Control #: US-0056LTR
• Format: Word; Rich Text

Description

This form is a sample letter in Word format covering the subject matter of the title of the form. [Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] [Sender's Name] [Sender's Address] [City, State, ZIP] Re: Response to Request for Production of Documents Dear [Sender's Name], I hope this letter finds you well. I am writing in response to your request for production of documents dated [insert date]. As per the rules of discovery governing the state of Delaware, I am hereby providing you with the requested documents within the specified time frame. 1. Preliminary Statement: I acknowledge your request for the production of documents pursuant to _____[reference specific statute, rule, or case law]. I have reviewed your request thoroughly and have diligently gathered the relevant documents for your review. 2. General Objections: I must raise a few general objections before providing the requested documents. These objections are made without waiving any rights, privileges, or objections based on relevance, admissibility, or any other grounds available under the applicable law. These objections are as follows: a. Over breadth: Your request is overly broad and unduly burdensome as it seeks documents that are not relevant to the subject at issue in this case. Nevertheless, I have made an effort to be cooperative and have provided the requested documents within this response. b. Unduly Voluminous: Your request seeks a large volume of documents that would require extensive resources and time to produce. Nonetheless, in an attempt to facilitate the discovery process, I have compiled the documents to the best of my abilities. c. Privilege and Confidentiality: Some requested documents may be protected by attorney-client privilege, work product doctrine, or other privileges recognized by Delaware law. I reserve the right to assert these privileges and objections throughout the entirety of this matter. 3. Specific Responses: Please find enclosed the documents requested in your letter. The following is a breakdown of the requested documents according to their respective categories: a. Category 1: [Specify the category of documents] — Document 1: [Description— - Document 2: [Description] — ... b. Category 2: [Specify the category of documents] — Document 1: [Description— - Document 2: [Description] — ... c. Category 3: [Specify the category of documents] — Document 1: [Description— - Document 2: [Description] — ... 4. Confidentiality and Protective Order: Considering the sensitive nature of some documents provided, I request that we enter into a confidentiality and protective order to ensure that the disclosed information remains protected from unauthorized disclosure or use. Please let me know if you are agreeable to such an order, and we can proceed accordingly. 5. Notice of Corrections and Supplemental Responses: I am aware that inadvertent mistakes or omissions may have occurred during the production process. Should I discover any corrections or supplemental responses, I undertake to provide them promptly, in accordance with the applicable discovery rules. Please be advised that this response is without prejudice and subject to revision or amendment upon a later determination of additional documents that are reasonably accessible, relevant, or responsive to your request. I trust that this response adequately addresses your request for production of documents. If you have any further inquiries or require clarification regarding these documents, please do not hesitate to contact me. Thank you for your attention to this matter. Sincerely, [Your Full Name]

[Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] [Sender's Name] [Sender's Address] [City, State, ZIP] Re: Response to Request for Production of Documents Dear [Sender's Name], I hope this letter finds you well. I am writing in response to your request for production of documents dated [insert date]. As per the rules of discovery governing the state of Delaware, I am hereby providing you with the requested documents within the specified time frame. 1. Preliminary Statement: I acknowledge your request for the production of documents pursuant to _____[reference specific statute, rule, or case law]. I have reviewed your request thoroughly and have diligently gathered the relevant documents for your review. 2. General Objections: I must raise a few general objections before providing the requested documents. These objections are made without waiving any rights, privileges, or objections based on relevance, admissibility, or any other grounds available under the applicable law. These objections are as follows: a. Over breadth: Your request is overly broad and unduly burdensome as it seeks documents that are not relevant to the subject at issue in this case. Nevertheless, I have made an effort to be cooperative and have provided the requested documents within this response. b. Unduly Voluminous: Your request seeks a large volume of documents that would require extensive resources and time to produce. Nonetheless, in an attempt to facilitate the discovery process, I have compiled the documents to the best of my abilities. c. Privilege and Confidentiality: Some requested documents may be protected by attorney-client privilege, work product doctrine, or other privileges recognized by Delaware law. I reserve the right to assert these privileges and objections throughout the entirety of this matter. 3. Specific Responses: Please find enclosed the documents requested in your letter. The following is a breakdown of the requested documents according to their respective categories: a. Category 1: [Specify the category of documents] — Document 1: [Description— - Document 2: [Description] — ... b. Category 2: [Specify the category of documents] — Document 1: [Description— - Document 2: [Description] — ... c. Category 3: [Specify the category of documents] — Document 1: [Description— - Document 2: [Description] — ... 4. Confidentiality and Protective Order: Considering the sensitive nature of some documents provided, I request that we enter into a confidentiality and protective order to ensure that the disclosed information remains protected from unauthorized disclosure or use. Please let me know if you are agreeable to such an order, and we can proceed accordingly. 5. Notice of Corrections and Supplemental Responses: I am aware that inadvertent mistakes or omissions may have occurred during the production process. Should I discover any corrections or supplemental responses, I undertake to provide them promptly, in accordance with the applicable discovery rules. Please be advised that this response is without prejudice and subject to revision or amendment upon a later determination of additional documents that are reasonably accessible, relevant, or responsive to your request. I trust that this response adequately addresses your request for production of documents. If you have any further inquiries or require clarification regarding these documents, please do not hesitate to contact me. Thank you for your attention to this matter. Sincerely, [Your Full Name]