New Jersey Sample Letter for Plaintiff's Motion for Protective Order, Motion to Quash, Objection to Notice of Deposition Duces Tecum

• Category: Letters - Legal - Documents
• State: Multi-State
• Control #: US-0892LTR
• Format: Word; Rich Text

Description

This form is a sample letter in Word format covering the subject matter of the title of the form. New Jersey Sample Letter for Plaintiff's Motion for Protective Order, Motion to Quash, Objection to Notice of Deposition Ducks Cecum: [Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] [Opposing Counsel's Name] [Opposing Counsel's Address] [City, State, ZIP] Re: Plaintiff's Motion for Protective Order, Motion to Quash, and Objection to Notice of Deposition Ducks Cecum Dear [Opposing Counsel's Name], I hope this letter finds you well. I am writing on behalf of [Plaintiff's Name], the plaintiff in the above-mentioned case, to address significant concerns regarding the recent Notice of Deposition Ducks Cecum served by your office on [Plaintiff's Name] on [Date]. I. Motion for Protective Order: We respectfully request that the court grant a protective order to limit the scope of the deposition and protect [Plaintiff's Name] from unnecessary harassment, annoyance, or undue burden. The current notice appears overly broad and unduly burdensome, requiring the production of documents beyond the reasonable scope of the case. In order to safeguard our client's rights, we request that the court restrict the scope of the deposition and clarify the specific categories of documents that can be requested. II. Motion to Quash: In addition to the motion for a protective order, we also move to quash the deposition notice altogether on grounds of [specific reason(s)]. [Provide detailed explanation and legal basis for the motion to quash]. We firmly believe that the aforementioned reasons demonstrate the necessity for the court to quash the deposition notice entirely. III. Objection to Notice of Deposition Ducks Cecum: Furthermore, we object to several aspects of the Notice of Deposition Ducks Cecum as it currently stands. [Specify objections based on relevance, proportionality, undue burden, etc.]. We believe that these objections are valid and should be considered by the court when deciding on the deposition's structure and document requests. We kindly request that you immediately respond to this letter to discuss potential alternatives to the deposition notice that would be more reasonable and just, taking into account our client's rights, the relevant rules of civil procedure, and the case's overall circumstances. If we do not receive a satisfactory response within [reasonable timeframe] from the date of this letter, we will have no choice but to seek relief from the court to protect our client's interests and preserve a fair litigation process. Thank you for your prompt attention to this matter. We look forward to receiving your response and working toward a resolution that is fair and just for both parties involved. Sincerely, [Your Name] [Your Law Firm's Name] [Your Law Firm's Address] [City, State, ZIP]

New Jersey Sample Letter for Plaintiff's Motion for Protective Order, Motion to Quash, Objection to Notice of Deposition Ducks Cecum: [Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] [Opposing Counsel's Name] [Opposing Counsel's Address] [City, State, ZIP] Re: Plaintiff's Motion for Protective Order, Motion to Quash, and Objection to Notice of Deposition Ducks Cecum Dear [Opposing Counsel's Name], I hope this letter finds you well. I am writing on behalf of [Plaintiff's Name], the plaintiff in the above-mentioned case, to address significant concerns regarding the recent Notice of Deposition Ducks Cecum served by your office on [Plaintiff's Name] on [Date]. I. Motion for Protective Order: We respectfully request that the court grant a protective order to limit the scope of the deposition and protect [Plaintiff's Name] from unnecessary harassment, annoyance, or undue burden. The current notice appears overly broad and unduly burdensome, requiring the production of documents beyond the reasonable scope of the case. In order to safeguard our client's rights, we request that the court restrict the scope of the deposition and clarify the specific categories of documents that can be requested. II. Motion to Quash: In addition to the motion for a protective order, we also move to quash the deposition notice altogether on grounds of [specific reason(s)]. [Provide detailed explanation and legal basis for the motion to quash]. We firmly believe that the aforementioned reasons demonstrate the necessity for the court to quash the deposition notice entirely. III. Objection to Notice of Deposition Ducks Cecum: Furthermore, we object to several aspects of the Notice of Deposition Ducks Cecum as it currently stands. [Specify objections based on relevance, proportionality, undue burden, etc.]. We believe that these objections are valid and should be considered by the court when deciding on the deposition's structure and document requests. We kindly request that you immediately respond to this letter to discuss potential alternatives to the deposition notice that would be more reasonable and just, taking into account our client's rights, the relevant rules of civil procedure, and the case's overall circumstances. If we do not receive a satisfactory response within [reasonable timeframe] from the date of this letter, we will have no choice but to seek relief from the court to protect our client's interests and preserve a fair litigation process. Thank you for your prompt attention to this matter. We look forward to receiving your response and working toward a resolution that is fair and just for both parties involved. Sincerely, [Your Name] [Your Law Firm's Name] [Your Law Firm's Address] [City, State, ZIP]