Subject: Request for Deposition — Discover— - [Case Name and Number] [Your Name] [Your Address] [City, State, ZIP Code] [Email Address] [Phone Number] [Date] [Opposing Party's Attorney Name] [Opposing Party's Attorney Firm Name] [Opposing Party's Attorney's Address] [City, State, ZIP Code] Dear [Opposing Party's Attorney's Name], RE: Request for Deposition — Discovery in the matter of [Case Name and Number] I hope this letter finds you well. I am writing to formally request your cooperation in scheduling a deposition for the purpose of discovery in connection with the above-mentioned case pending in [State and Court]. As you may be aware, depositions play a crucial role in obtaining relevant and material information to prepare our respective clients for the trial. Understanding the importance of a fair and just legal process, I am kindly seeking your cooperation to facilitate the following deposition(s): 1. GENERAL DISCOVERY DEPOSITION I request to depose [Name of the Deposition Witness], who I believe possesses information that is relevant and material to the claims and defenses in this case. The proposed deposition will be conducted in accordance with the applicable laws and rules of civil procedure, ensuring that both parties have an equal opportunity to obtain the necessary information for their respective cases. The deposition is planned to take place at a mutually agreed-upon location within the state of Hawaii. Alternatively, I am open to discussing other arrangements if you find it more convenient or necessary. 2. EXPERT WITNESS DISCOVERY DEPOSITION If applicable, I also request to depose any expert witnesses that you may present as part of your case. The deposition(s) will contribute to a comprehensive understanding of the expert's opinions, methodologies, qualifications, and any other factors that impact their credibility and relevance to the case. As with the general discovery deposition, I am open to discussing the logistics and details of scheduling to ensure a smooth and efficient process. To proceed with the deposition(s), I kindly request the following: 1. Provide the available dates and time slots within the next [reasonable timeframe, e.g., 30 days] that you or your client's representative would be available for the deposition(s). 2. Share the contact details of the individuals representing your client during the deposition(s). 3. Confirm whether any specific instructions or requests are necessary regarding the format or structure of the deposition(s). Please consider this letter as a good-faith effort to move forward with the discovery process and promote a cooperative and efficient litigation experience for both parties involved. I look forward to your prompt response and cooperation in scheduling these depositions at the earliest mutually convenient date. If you have any questions or concerns regarding this request, please feel free to contact me at [Your Phone Number] or [Your Email Address]. Thank you for your attention to this matter. Sincerely, [Your Name] [Your Attorney Firm Name, if applicable] [Your Attorney Bar Number, if applicable]