[Your Name] [Your Address] [City, State, Zip Code] [Email Address] [Phone Number] [Date] [Defendant's Name] [Defendant's Address] [City, State, Zip Code] Re: [Case Name/Number] Dear [Defendant's Name], I am writing in response to your First Set of Interrogatories and First Request for Production of Documents, dated [date]. I acknowledge receipt of the aforementioned interrogatories and document requests on behalf of my client, [Your Client's Name], and thank you for providing them within the required timeframe. However, due to the complexity and volume of the requested information, we kindly request an extension of time to adequately respond to your interrogatories and produce the requested documents. It is essential that we are able to provide comprehensive and accurate responses, and we anticipate that additional time is required to gather the necessary information and thoroughly address each inquiry. Given the circumstances, we kindly request a [specific number of days/weeks] extension, whereby the new deadline for our response would be [proposed due date]. This additional time will enable us to prepare a comprehensive and timely response that will assist in the orderly progression of this case. We assure you that we understand our obligation to respond in a timely manner and are committed to fulfilling our obligations as mandated by the rules of discovery. By requesting this extension, we seek to ensure the integrity of our responses without causing undue delay in the legal proceedings. If you have any objections or concerns regarding our request for an extension, please notify us promptly so that we can discuss the matter further and explore potential alternatives to address the issue. Thank you for your understanding and cooperation in this matter. We look forward to receiving your favorable response so that we may proceed with the necessary preparations to diligently respond to your interrogatories and produce the requested documents by the proposed due date. Please kindly confirm your consent to the extension by signing and returning a copy of this letter at your earliest convenience. Sincerely, [Your Name] [Your Title] [Law Firm Name] [Law Firm Address] [City, State, Zip Code] [Email Address] [Phone Number] cc: [Your Client's Name]