Louisiana Discovery - Sample Letter to Opposing Counsel regarding Deposition and Subpoena Duces Tecum

• Category: Letters - Legal - Discovery
• State: Multi-State
• Control #: US-0480LTR
• Format: Word; Rich Text

Description

This form is a sample letter in Word format covering the subject matter of the title of the form. Subject: Louisiana Discovery — Sample Letter to Opposing Counsel regarding Deposition and Subpoena Ducks Cecum Dear [Opposing Counsel's Name], I hope this letter finds you well. In regard to the ongoing litigation between our respective clients, I am writing to discuss and request your cooperation in the Louisiana discovery process, specifically regarding the deposition and subpoena duces tecum. 1. Deposition: A deposition is a crucial aspect of the discovery process in Louisiana, enabling both parties to gather essential information and testimonies from witnesses under oath. In accordance with Louisiana Code of Civil Procedure § 1431 et seq., we kindly request that you arrange for the deposition of the involved party(Witness's Name) on [Date] at [Time] at [Location]. Please confirm the availability of the mentioned witness and propose an alternative time and location, or any videoconference arrangement, if necessary. 2. Subpoena Ducks Cecum: To ensure a comprehensive discovery, we request the production of relevant documents and records under the subpoena duces tecum provision. As prescribed by Louisiana Code of Civil Procedure § 1461 et seq., we are enclosing a copy of the subpoena duces tecum, along with a list of specific items we seek to obtain. These documents may include, but are not limited to: a. Any written agreements, contracts, or correspondence related to the case. b. Financial records, such as bank statements, tax returns, or invoices relevant to the subject. c. Employment records, including employee files, payroll information, or disciplinary records as they pertain to any involved parties. d. Any photographs, videos, or audio recordings that are potentially relevant to the case. e. Medical records, bills, or reports, if applicable. f. Any relevant electronic evidence, including emails, text messages, or social media posts. Please arrange for the production of these documents within [a reasonable time frame], either by providing copies to us directly or suggesting a mutually agreed-upon location for inspection. Kindly note that, pursuant to Louisiana law, any objections to these requests must be made in writing within 15 days of receiving this letter. Failure to raise timely objections may result in a waiver of your client's rights to challenge admissibility or relevance at a later date. Should you have any concerns or require additional information regarding the deposition or subpoena duces tecum, do not hesitate to contact me. It is our shared responsibility to ensure a smooth and efficient discovery process while promoting transparency and fair access to relevant evidence. Thank you for your prompt attention to this matter, and I look forward to receiving your response within [a reasonable time frame]. Sincerely, [Your Name] [Your Law Firm's Name] [Contact Information]

Subject: Louisiana Discovery — Sample Letter to Opposing Counsel regarding Deposition and Subpoena Ducks Cecum Dear [Opposing Counsel's Name], I hope this letter finds you well. In regard to the ongoing litigation between our respective clients, I am writing to discuss and request your cooperation in the Louisiana discovery process, specifically regarding the deposition and subpoena duces tecum. 1. Deposition: A deposition is a crucial aspect of the discovery process in Louisiana, enabling both parties to gather essential information and testimonies from witnesses under oath. In accordance with Louisiana Code of Civil Procedure § 1431 et seq., we kindly request that you arrange for the deposition of the involved party(Witness's Name) on [Date] at [Time] at [Location]. Please confirm the availability of the mentioned witness and propose an alternative time and location, or any videoconference arrangement, if necessary. 2. Subpoena Ducks Cecum: To ensure a comprehensive discovery, we request the production of relevant documents and records under the subpoena duces tecum provision. As prescribed by Louisiana Code of Civil Procedure § 1461 et seq., we are enclosing a copy of the subpoena duces tecum, along with a list of specific items we seek to obtain. These documents may include, but are not limited to: a. Any written agreements, contracts, or correspondence related to the case. b. Financial records, such as bank statements, tax returns, or invoices relevant to the subject. c. Employment records, including employee files, payroll information, or disciplinary records as they pertain to any involved parties. d. Any photographs, videos, or audio recordings that are potentially relevant to the case. e. Medical records, bills, or reports, if applicable. f. Any relevant electronic evidence, including emails, text messages, or social media posts. Please arrange for the production of these documents within [a reasonable time frame], either by providing copies to us directly or suggesting a mutually agreed-upon location for inspection. Kindly note that, pursuant to Louisiana law, any objections to these requests must be made in writing within 15 days of receiving this letter. Failure to raise timely objections may result in a waiver of your client's rights to challenge admissibility or relevance at a later date. Should you have any concerns or require additional information regarding the deposition or subpoena duces tecum, do not hesitate to contact me. It is our shared responsibility to ensure a smooth and efficient discovery process while promoting transparency and fair access to relevant evidence. Thank you for your prompt attention to this matter, and I look forward to receiving your response within [a reasonable time frame]. Sincerely, [Your Name] [Your Law Firm's Name] [Contact Information]