[Your Name] [Your Address] [City, State, Zip Code] [Email Address] [Phone Number] [Date] [Client's Name] [Client's Address] [City, State, Zip Code] Re: Instructing on Answering Discovery Requests — [Case Name/Number] Dear [Client's Name], I hope this letter finds you well. I am writing to provide you with specific instructions on how to effectively respond to the discovery requests we have received in relation to your case. As you are aware, discovery is a crucial aspect of the litigation process, and it is imperative that we respond in a timely and thorough manner. Types of Discovery Requests: 1. Interrogatories: These are written questions that the opposing party submits to gather information about the case. You are required to provide complete and accurate answers within [timeframe specified in court rules]. 2. Requests for Production of Documents: The opposing party may request documents or other tangible evidence relevant to the case. Please carefully review each request and produce the requested documents within [timeframe specified in court rules]. 3. Requests for Admissions: These are statements that require you to either admit or deny certain facts or allegations. You must respond to each admission request within [timeframe specified in court rules], admitting or denying the statements appropriately. Instructions for Responding to Discovery Requests: 1. Thoroughly review the discovery requests: Carefully read each question or request to ensure a proper understanding of what information or documents are being sought. Take note of any specific instructions or limitations mentioned. 2. Seek guidance from your attorney: If you have any doubts or concerns regarding a particular question or request, please reach out to me for clarification. It is crucial to provide accurate and legally appropriate responses. 3. Provide complete and honest answers: When answering interrogatories, be truthful and comprehensive in your responses. Avoid volunteering unnecessary information or offering speculative opinions. Stick to the facts you know to the best of your ability. 4. Organize and label documents: When responding to requests for production of documents, systematically arrange relevant documents in an organized manner. Label each document clearly and provide an index that corresponds to the requests made. 5. Admit or deny appropriately: When responding to requests for admissions, carefully consider each statement and admit or deny it in a straightforward manner. Failure to respond to admissions will result in the court deeming them admitted. 6. Keep copies of all responses: Make copies of all the responses provided, both in written and electronic format, for your records. This will help us review the information provided and ensure nothing is missed or overlooked. 7. Review for accuracy and completeness: Before submitting the responses, review them to verify that they are accurate, complete, and responsive to the discovery requests. Correct any errors or omissions promptly. Please note that non-compliance with discovery requests can have adverse consequences for our case. It is essential to meet the stated deadlines and provide accurate and exhaustive responses. Should you have any questions or require further clarification, do not hesitate to contact me. Together, we will navigate through these discovery requests efficiently and ensure our case is as strong as possible. Thank you for your ongoing cooperation and support. Sincerely, [Your Name] [Your Law Firm's Name]