Nebraska Discovery — Sample Letter to Opposing Counsel regarding Deposition and Subpoena Ducks Cecum [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: Deposition and Subpoena Ducks Cecum Dear [Opposing Counsel's Name], I hope this letter finds you well. I am writing to inform you of my intent to conduct a deposition and issue a subpoena duces tecum in the ongoing litigation between our respective clients, [Plaintiff's Name] and [Defendant's Name]. This letter aims to outline the details and requirements for proper execution of these discovery tools in compliance with Nebraska laws and regulations. 1. Deposition: As part of the discovery process, we would like to schedule a deposition with [Witness's Name] to obtain their testimony under oath. This deposition is crucial to uncovering relevant facts and clarifying issues pertinent to the case. According to Nebraska law, a deposition may be taken upon oral examination of any person, including a party, who has knowledge of discoverable information. The deposition will take place at [Location], on [Date] at [Time]. Our office would like to propose [Name of Court Reporter] as the certified court reporter to transcribe the proceedings. Please confirm your agreement with the proposed deposition date and location and provide the name of the attorney who will represent your client at the deposition. 2. Subpoena Ducks Cecum: To further support our client's position, we hereby issue a subpoena duces tecum to request the production of specific documents and materials relevant to the case. These documents include, but are not limited to: — [List of specific documents— - [List of specific materials] The subpoena requests that the documents and materials be produced on or before [Date]. As per Nebraska law, this can be done by either delivering the documents to my office or making them available for inspection and copying at a mutually agreed-upon location. Please confirm your acceptance of the subpoena and provide any objections or limitations within the designated time frame. In both instances, please be mindful of your obligations under the Nebraska Discovery Rules. This includes promptly informing your client of the scheduled deposition, as well as providing all requested documents and materials in an organized and discoverable format. We trust that you will cooperate fully in facilitating these essential discovery processes. If you have any concerns, objections, or need clarification on any matter related to this letter, please do not hesitate to contact me at your earliest convenience. We also welcome an open discussion regarding potential modifications to the proposed deposition and subpoena schedules. Thank you for your attention to this matter, and we look forward to your prompt response. Sincerely, [Your Name] [Your Title/Position] [Your Law Firm Name]