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] [Judge's Name] [Judge's Designation] [Delaware Court Name] [Court Address] [City, State, ZIP] Re: Case No. [Case Number]: Plaintiff's Motion to Compel Answers to Plaintiff's Second Set of Interrogatories Dear [Judge's Last Name], I hope this letter finds you in good health and high spirits. I, [Your Name], on behalf of the plaintiff in the above-mentioned case, respectfully submit this motion to compel the defendant's responses to the plaintiff's second set of interrogatories. I request the court's attention to this matter to ensure an equitable and expedient resolution. Summary of Background: 1. The plaintiff initiated this lawsuit seeking [mention nature of the lawsuit briefly]. 2. By virtue of the Delaware Court Rules, the plaintiff served the defendant a valid and legally sound second set of interrogatories on [date]. 3. Pursuant to Delaware Civil Rule [mention applicable rule number], the defendant was required to respond within [mention required response time as per the rule]. 4. However, to date, the defendant has failed to provide any response or objection, demonstrating a clear disregard for their obligations under Delaware procedural rules. Legal Basis for Motion: 1. Delaware Civil Rule [mention applicable rule number] grants the plaintiff the right to serve interrogatories to the opposing party to elicit relevant information. 2. Delaware Civil Rule [mention applicable rule number] mandates that the opposing party must respond to interrogatories within the stipulated timeframe or object based on valid grounds. 3. In this case, the defendant's failure to respond or object to the plaintiff's second set of interrogatories constitutes a violation of Delaware procedural rules. Pertinent Arguments: 1. The plaintiff's second set of interrogatories seek relevant information crucial to the resolution of this case [provide specific examples of questions and their relevance]. 2. By failing to respond or object, the defendant is purposefully impeding the discovery process, causing unnecessary delays, and hampering the just resolution of this matter. 3. The defendant should not be allowed to evade their discovery obligations and prevent the plaintiff from obtaining the necessary information to present their case effectively. Relief Sought: 1. The plaintiff requests the court to grant the following relief: a. Order the defendant to produce complete and substantive responses to the plaintiff's second set of interrogatories within [mention reasonable timeframe]. b. In the event the defendant fails to respond within the given timeframe, impose appropriate sanctions, as authorized by Delaware procedural rules, to deter further non-compliance. Conclusion: In light of the defendant's unjustifiable failure to respond or object to the plaintiff's second set of interrogatories, I respectfully urge this honorable court to grant the motion to compel and ensure the defendant's compliance with the discovery process. The plaintiff seeks a fair opportunity to present their case and achieve a just resolution. Thank you for your time and attention to this matter. I would be available at any time to provide additional information or appear for a hearing if required. Furthermore, please find enclosed a proposed order for the court's convenience. Yours sincerely, [Your Name] [Your Bar Number] (if applicable)
[Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] [Judge's Name] [Judge's Designation] [Delaware Court Name] [Court Address] [City, State, ZIP] Re: Case No. [Case Number]: Plaintiff's Motion to Compel Answers to Plaintiff's Second Set of Interrogatories Dear [Judge's Last Name], I hope this letter finds you in good health and high spirits. I, [Your Name], on behalf of the plaintiff in the above-mentioned case, respectfully submit this motion to compel the defendant's responses to the plaintiff's second set of interrogatories. I request the court's attention to this matter to ensure an equitable and expedient resolution. Summary of Background: 1. The plaintiff initiated this lawsuit seeking [mention nature of the lawsuit briefly]. 2. By virtue of the Delaware Court Rules, the plaintiff served the defendant a valid and legally sound second set of interrogatories on [date]. 3. Pursuant to Delaware Civil Rule [mention applicable rule number], the defendant was required to respond within [mention required response time as per the rule]. 4. However, to date, the defendant has failed to provide any response or objection, demonstrating a clear disregard for their obligations under Delaware procedural rules. Legal Basis for Motion: 1. Delaware Civil Rule [mention applicable rule number] grants the plaintiff the right to serve interrogatories to the opposing party to elicit relevant information. 2. Delaware Civil Rule [mention applicable rule number] mandates that the opposing party must respond to interrogatories within the stipulated timeframe or object based on valid grounds. 3. In this case, the defendant's failure to respond or object to the plaintiff's second set of interrogatories constitutes a violation of Delaware procedural rules. Pertinent Arguments: 1. The plaintiff's second set of interrogatories seek relevant information crucial to the resolution of this case [provide specific examples of questions and their relevance]. 2. By failing to respond or object, the defendant is purposefully impeding the discovery process, causing unnecessary delays, and hampering the just resolution of this matter. 3. The defendant should not be allowed to evade their discovery obligations and prevent the plaintiff from obtaining the necessary information to present their case effectively. Relief Sought: 1. The plaintiff requests the court to grant the following relief: a. Order the defendant to produce complete and substantive responses to the plaintiff's second set of interrogatories within [mention reasonable timeframe]. b. In the event the defendant fails to respond within the given timeframe, impose appropriate sanctions, as authorized by Delaware procedural rules, to deter further non-compliance. Conclusion: In light of the defendant's unjustifiable failure to respond or object to the plaintiff's second set of interrogatories, I respectfully urge this honorable court to grant the motion to compel and ensure the defendant's compliance with the discovery process. The plaintiff seeks a fair opportunity to present their case and achieve a just resolution. Thank you for your time and attention to this matter. I would be available at any time to provide additional information or appear for a hearing if required. Furthermore, please find enclosed a proposed order for the court's convenience. Yours sincerely, [Your Name] [Your Bar Number] (if applicable)