[Your Name] [Your Address] [City, State, ZIP Code] [Email Address] [Phone Number] [Date] [Recipient's Name] [Recipient's Designation] [Recipient's Address] [City, State, ZIP Code] Re: Plaintiff's Motion to Compel Answers to Plaintiff's Second Set of Interrogatories Dear [Recipient's Name], I hope this letter finds you well. I am writing to bring to your attention the need to promptly respond to Plaintiff's Second Set of Interrogatories in the above-mentioned case. As the plaintiff's attorney, I am compelled to file this Motion to Compel Answers in order to ensure a fair and just resolution to our client's claims. As you are aware, New Hampshire law requires each party to engage in the process of discovery, wherein interrogatories are served to facilitate the exchange of crucial information relevant to the case. Unfortunately, despite the passage of the deadline for responses, we have not received any correspondence or written answers to the interrogatories we served upon you on [date of serving interrogatories]. It is essential for all parties involved in this litigation to comply with their obligations to participate in discovery. By failing to provide the requested responses, you hinder the progress of the case, create unnecessary delays, and compromise the ability to achieve a fair trial or settlement. Therefore, pursuant to New Hampshire Rules of Civil Procedure, Rule [XYZ], I kindly request that you promptly provide written answers to Plaintiff's Second Set of Interrogatories. The answers should be thorough, in compliance with the applicable rules, and should contain all relevant information within your knowledge, possession, or control. Failure to comply with this motion may result in more severe measures, including sanctions, adverse inferences, or other remedies available under the New Hampshire Rules of Civil Procedure. Please be advised that if you intend to oppose this motion, you must submit a written response no later than [deadline for response to this letter], detailing your reasons for non-compliance or objections to our interrogatories. Failure to respond may be deemed as an admission of the appropriateness of this motion. Kindly acknowledge receipt of this letter and confirm your intentions regarding the requested responses within [acceptable timeframe, typically 10 days] from the date of this letter. Timeliness in resolving this matter will highly contribute to ensuring the effectiveness and efficiency of the judicial process. Thank you for your prompt attention to this matter. I hope we can work together to promptly bring resolution to this discovery issue and continue with the litigation process. Should you have any questions or concerns, please do not hesitate to contact me at [your phone number] or [your email address]. I look forward to resolving this matter cooperatively. Yours sincerely, [Your Name] [Your Title/Designation] [Your Law Firm's Name]
New Hampshire Sample Letter for Plaintiff's Motion to Compel Answers to Plaintiff's Second Set of Interrogatories
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How to fill out New Hampshire Sample Letter For Plaintiff's Motion To Compel Answers To Plaintiff's Second Set Of Interrogatories?
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Deadline 45 days: Motion to Compel must be filed within 45 days from insufficient response [See Above].
What Happens After a Motion to Compel is Filed? Once a motion to compel is filed, the court will review it and determine whether a hearing is necessary. The court may also issue an order requiring the other party to respond to the motion.
Your answers to the interrogatories should usually be short, clear, and direct and should answer only the question that is being asked. This is not the time to set out your entire case or defense to the other side. Take the time to make sure your answers are correct and truthful.
A motion to compel further responses to interrogatories is a prime example. (This is where you've received responses to interrogatories, believe them to be incomplete, and you want the court to order the responding party to provide further responses.)
However, you can object to interrogatories that call for legal conclusions. You can also object to questions if they are not at all related to the court case. To object, you need to write out the reasons for the objection instead of answering the question.
When that happens, a party can file a motion to compel, asking the Court to order the opposing party to produce the contested documents or information. If a motion to compel is granted and the Court orders the information produced, failing to comply with that order can lead to serious consequences.
We don't like Motions to Compel. Judges don't like them, and neither do the opposing parties we bring them against. But they are, sometimes, required to be brought in cases where you need information to make sure you know what facts, witnesses and documents are in a case prior to going to going to trial.
(b) Good Faith Efforts to Confer Before a party files a motion to compel a response to discovery, the party must make a good faith effort to confer with the person or party allegedly failing to properly respond to a request for discovery in an effort to secure information or material without action by the ALJ.
