[Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] [Opposing Counsel's Name] [Opposing Counsel's Law Firm] [Address] [City, State, ZIP] Re: Responses to Request for Production of Documents Case Name: [Case Name] Case Number: [Case Number] Dear [Opposing Counsel's Name], I hope this letter finds you well. I am writing in response to your Request for Production of Documents dated [Date], as part of the discovery process in the above-mentioned case. As per the Rules of Civil Procedure for the State of North Carolina, I am required to provide the requested documents within a reasonable time frame. Please find enclosed my responses to each document request as outlined below: [Document Request No. 1] Description: [Provide a brief description of the requested document] Response: [State whether the document will be produced, object to the request, or claim privilege] Explanation: [If applicable, explain the reason for any objections or claims of privilege] [Document Request No. 2] Description: [Provide a brief description of the requested document] Response: [State whether the document will be produced, object to the request, or claim privilege] Explanation: [If applicable, explain the reason for any objections or claims of privilege] [Continue listing each Document Request and their corresponding Response and Explanation, as necessary] I would like to bring to your attention that some documents requested may be privileged or protected by applicable laws. Upon review, if any such documents are identified, I will either assert privilege or provide an appropriate explanation for the objection in accordance with the applicable rules. Furthermore, I would appreciate it if you could reciprocate by providing your responses to my Request for Production of Documents, which was served on [Date]. It is crucial for both parties to engage in a fair and transparent discovery process to ensure a smooth progression of this case. Please consider this correspondence as an attempt to work collaboratively and in good faith. Nevertheless, if an agreement cannot be reached or if further clarification is required, I am open to discussing the matter further or scheduling a meet-and-confer session to address any concerns. Kindly acknowledge receipt of this letter within [Number of Days] from the date of receipt, as per the North Carolina Rules of Civil Procedure. If you have any questions or need additional information, please do not hesitate to contact me via email or phone. Thank you for your attention to this matter. Yours sincerely, [Your Name]