Subject: Comprehensive Description of Delaware Sample Letter for Unavailable 30(b)(6) Representative Dear [Recipient's Name], I hope this letter finds you well. I am writing to provide you with a detailed description of the Delaware Sample Letter for situations where a 30(b)(6) representative is not available. This letter aims to assist you in understanding the process and requirements when encountering this specific scenario. In legal proceedings, a 30(b)(6) deposition notice allows a party to request the appearance of an organization's designated representative to provide testimony or produce documents related to certain specified topics. However, there may be instances where the designated representative is either unavailable or cannot fulfill the requested duties. When faced with an unavailable or unresponsive 30(b)(6) representative, legal practitioners in Delaware may employ a sample letter to address the issue. The purpose of this letter is to inform opposing counsel that a suitable representative cannot be produced due to various reasons. It is crucial to emphasize that this sample letter should be customized according to the specific circumstances of the case and compliance with any applicable rules or court orders. The Delaware Sample Letter for an Unavailable 30(b)(6) Representative generally follows a structured format: 1. Heading: Begin the letter by stating the sender's contact details, including name, address, phone number, and email address. Similarly, provide the recipient's details, including their name, law firm, address, etc. 2. Salutation: Address the opposing counsel formally, using their professional title and last name. 3. Introduction: Provide a brief background of the ongoing litigation and mention the relevant topics or areas for which the 30(b)(6) deposition was initially sought. 4. Explanation of Unavailability: Articulate the reasons for the non-availability of a suitable representative. Common reasons might include illness, disengagement from the organization, or unavailability during the required deposition time frame. Be careful not to disclose any privileged or confidential information. 5. Good Faith Efforts: Highlight the steps taken in good faith to locate or appoint a replacement representative, such as reaching out to other potential individuals within the organization or notifying higher management about the proceedings. 6. Request for Cooperation: Request the opposing party's understanding and cooperation in light of these unforeseen circumstances. Propose alternative options, such as rescheduling the deposition or narrowing down the topics to a manageable subset. 7. Closing Remarks: Express appreciation for the recipient's attention to this matter and willingness to resolve the issue. Conclude the letter with a professional closing and the sender's signature. It is important to note that this Delaware Sample Letter for an Unavailable 30(b)(6) Representative does not constitute legal advice and should be used as a reference only. Each legal matter may have unique requirements, so it is crucial to consult with your legal counsel to tailor the letter to fit the specific circumstances of your case. Please feel free to reach out if you require any further assistance or clarification regarding this Delaware Sample Letter. We are here to support you throughout your legal proceedings. Best regards, [Your Name] [Your Title/Organization] [Contact Information] [Date]