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

State:
Multi-State
Control #:
US-0480LTR
Format:
Word; 
Rich Text
Instant download

Description

This form is a sample letter in Word format covering the subject matter of the title of the form. Keywords: Michigan discovery, sample letter, opposing counsel, deposition, subpoena duces tecum Sample Letter to Opposing Counsel Regarding Deposition and Subpoena Ducks Cecum in Michigan Discovery [Your Name] [Your Law Firm] [Address] [City, State, ZIP Code] [Phone Number] [Email Address] [Date] [Opposing Counsel's Name] [Opposing Counsel's Law Firm] [Address] [City, State, ZIP Code] Re: Case Name/Number — Request for Deposition and SubpoenDuckses Cecum Dear [Opposing Counsel's Name], I am writing to formally request your cooperation in scheduling a deposition and the issuance of a subpoena duces tecum in relation to the above-mentioned case pending before [Court Name]. As both parties have a duty to engage in the discovery process, we kindly urge your prompt attention to this matter. 1. Deposition: In order to gather crucial information and clarify various aspects of the case, we request your agreement to the scheduling of a deposition with [Witness Name]. The deposition will be held at a mutually agreeable time and place, in accordance with the Michigan Court Rules. As per the rules, we are responsible for selecting the location, and we will ensure that it is convenient for all participants. Please provide us with the dates and times that generally work best for you and your client, and we will attempt to accommodate your schedule as much as possible. Additionally, if there are any specific topics or areas you suggest covering during the deposition, kindly inform us beforehand to facilitate a productive and efficient proceeding. 2. Subpoena Ducks Cecum: We also seek your consent to issue a subpoena duces tecum, compelling the production of specific documents or materials that are relevant and material to our case. The requested documents can include, but are not limited to, [describe the type of documents or materials sought], as further outlined in the attached document list. We understand that Michigan's discovery rules require reasonable notice for the production of documents. Upon receiving your agreement, we will promptly prepare and serve the subpoena duces tecum, ensuring compliance with all legal requirements. 3. Cooperation and Procedural Suggestions: As officers of the court, it is essential that we work together to ensure a fair and thorough discovery process. In this spirit, we propose the following suggestions to promote efficiency and cooperation: a. Agreeing on a reasonable timeframe for document production following the issuance of the subpoena duces tecum. b. Considering any potential objections to the requested documents and resolving them in good faith prior to the deposition. c. Cooperating in the efficient use of technology, such as video conferencing, if appropriate and agreed upon, to minimize travel costs and inconvenience. We believe that adopting these recommendations will not only serve the interests of our respective clients but also promote the swift resolution of this litigation. Please acknowledge receipt of this letter by [Date]. If you have any questions or concerns, or if you would like to discuss alternative arrangements, kindly contact me directly at [Phone Number] or via email at [Email Address]. Thank you for your attention to this matter. We look forward to your prompt response and to proceeding with the discovery process as soon as possible. Sincerely, [Your Name] [Your Law Firm] Enclosure: Document List (if applicable)

Keywords: Michigan discovery, sample letter, opposing counsel, deposition, subpoena duces tecum Sample Letter to Opposing Counsel Regarding Deposition and Subpoena Ducks Cecum in Michigan Discovery [Your Name] [Your Law Firm] [Address] [City, State, ZIP Code] [Phone Number] [Email Address] [Date] [Opposing Counsel's Name] [Opposing Counsel's Law Firm] [Address] [City, State, ZIP Code] Re: Case Name/Number — Request for Deposition and SubpoenDuckses Cecum Dear [Opposing Counsel's Name], I am writing to formally request your cooperation in scheduling a deposition and the issuance of a subpoena duces tecum in relation to the above-mentioned case pending before [Court Name]. As both parties have a duty to engage in the discovery process, we kindly urge your prompt attention to this matter. 1. Deposition: In order to gather crucial information and clarify various aspects of the case, we request your agreement to the scheduling of a deposition with [Witness Name]. The deposition will be held at a mutually agreeable time and place, in accordance with the Michigan Court Rules. As per the rules, we are responsible for selecting the location, and we will ensure that it is convenient for all participants. Please provide us with the dates and times that generally work best for you and your client, and we will attempt to accommodate your schedule as much as possible. Additionally, if there are any specific topics or areas you suggest covering during the deposition, kindly inform us beforehand to facilitate a productive and efficient proceeding. 2. Subpoena Ducks Cecum: We also seek your consent to issue a subpoena duces tecum, compelling the production of specific documents or materials that are relevant and material to our case. The requested documents can include, but are not limited to, [describe the type of documents or materials sought], as further outlined in the attached document list. We understand that Michigan's discovery rules require reasonable notice for the production of documents. Upon receiving your agreement, we will promptly prepare and serve the subpoena duces tecum, ensuring compliance with all legal requirements. 3. Cooperation and Procedural Suggestions: As officers of the court, it is essential that we work together to ensure a fair and thorough discovery process. In this spirit, we propose the following suggestions to promote efficiency and cooperation: a. Agreeing on a reasonable timeframe for document production following the issuance of the subpoena duces tecum. b. Considering any potential objections to the requested documents and resolving them in good faith prior to the deposition. c. Cooperating in the efficient use of technology, such as video conferencing, if appropriate and agreed upon, to minimize travel costs and inconvenience. We believe that adopting these recommendations will not only serve the interests of our respective clients but also promote the swift resolution of this litigation. Please acknowledge receipt of this letter by [Date]. If you have any questions or concerns, or if you would like to discuss alternative arrangements, kindly contact me directly at [Phone Number] or via email at [Email Address]. Thank you for your attention to this matter. We look forward to your prompt response and to proceeding with the discovery process as soon as possible. Sincerely, [Your Name] [Your Law Firm] Enclosure: Document List (if applicable)

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