[Your Name] [Your Address] [City, State, Zip Code] [Email Address] [Phone Number] [Date] [Defendant's Name] [Defendant's Address] [City, State, Zip Code] Re: [Case Title or Number] Dear [Defendant's Name], I hope this letter finds you well. I am writing to formally request an extension of time to respond to your First Set of Interrogatories and First Request for Production of Documents, as served on [date of service]. Due to the complexity and volume of the requested information, as well as other ongoing legal obligations and caseload, it would be unreasonable for us to meet the original deadline prescribed by the Rules of Civil Procedure. We believe that by granting this extension, it will enable us to adequately review and gather the requested documents and information, ensuring a comprehensive and accurate response. We acknowledge the importance of complying with your discovery requests in a timely manner, and we assure you that we are committed to providing all necessary information within a reasonable timeframe. Therefore, we respectfully request a [number of days] extension for responding to the Interrogatories and Request for Production. We understand the need for cooperation in this matter, and as such, we will provide you with regular updates on our progress and expected timeline for completing our response. Please confirm your agreement to this extension by signing and returning a copy of this letter within [number of days] of receipt. A faxed or scanned copy of the signed agreement will be sufficient. Thank you for your kind consideration of this request. We believe that this extension of time will allow both parties to fully comply with their legal duties, facilitating a fair and efficient resolution of the case. If you have any questions or need any further information, please do not hesitate to contact me directly. We look forward to continuing our cooperation throughout this discovery process. Sincerely, [Your Name] [Your Title/Position] [Your Law Firm's Name] [Your Law Firm's Address] [City, State, Zip Code] [Email Address] [Phone Number]