New Mexico Sample Letter for First Interrogatories and First Set of Request for Production of Documents

• Category: Letters - Legal - Counterclaims
• State: Multi-State
• Control #: US-0230LTR
• Format: Word; Rich Text

Description

This form is a sample letter in Word format covering the subject matter of the title of the form. [Your Name] [Your Address] [City, State, Zip Code] [Email Address] [Phone Number] [Date] [Opposing Party's Name] [Opposing Party's Address] [City, State, Zip Code] Subject: First Interrogatories and Request for Production of Documents Dear [Opposing Party's Name], I hope this letter finds you well. I am writing to serve you with the First Interrogatories and Request for Production of Documents in relation to the ongoing matter [Case Number/Title] pending in [Court Name]. As per the Rules of Civil Procedure in New Mexico, I kindly request your timely response to the following interrogatories and document requests, within [number of days] of receiving this letter. Interrogatories: 1. Please state your full legal name, current address, telephone number, and occupation. 2. Please identify any individuals with knowledge of the facts surrounding [Case Number/Title] and provide their full names, addresses, and telephone numbers. 3. Identify all witnesses you intend to call at trial, providing their full names, addresses, and telephone numbers. 4. Please describe in detail your version of the events leading up to and surrounding [Case Number/Title]. 5. Please identify and provide copies of any written agreements or contracts relevant to [Case Number/Title], including any amendments or modifications. 6. Identify any expert witnesses you intend to call at trial, providing their full names, addresses, areas of expertise, and a summary of their expected testimony. 7. Identify any insurance coverage you hold that may be applicable to [Case Number/Title], including the name of the insurance company and policy number. Request for Production of Documents: 1. Please produce all documents, including contracts, letters, emails, and faxes, relating to [Case Number/Title], from [specific dates or timeframe]. 2. Provide copies of all medical records, invoices, and bills related to any injuries or medical treatment associated with [Case Number/Title]. 3. Produce all photographs, videos, or other visual recordings that depict the scene of the incident and/or your alleged injuries. 4. Provide copies of all relevant financial records, such as tax returns, bank statements, and pay stubs, over the past [specific years or timeframe]. 5. Please provide any insurance policies, including automobile, homeowners, or business policies, that may be applicable to [Case Number/Title]. 6. Produce any written statements, reports, or correspondence from expert witnesses retained or consulted in relation to [Case Number/Title]. Please note that these interrogatories and document requests pertain solely to the matters at hand and are expected to be treated pursuant to the applicable rules and procedures of New Mexico. Failure to timely and fully respond to these interrogatories and document requests may result in appropriate motions being filed with the court to compel discovery. Your timely and comprehensive responses are highly appreciated, as they will facilitate the process of resolving this matter efficiently and fairly. Should you require any clarification or have any concerns regarding these interrogatories and document requests, please do not hesitate to contact my office. Thank you for your attention to this matter, and I look forward to receiving your response by [deadline]. Sincerely, [Your Name] [Your Law Firm, if applicable] [Your Bar Number, if applicable]

[Your Name] [Your Address] [City, State, Zip Code] [Email Address] [Phone Number] [Date] [Opposing Party's Name] [Opposing Party's Address] [City, State, Zip Code] Subject: First Interrogatories and Request for Production of Documents Dear [Opposing Party's Name], I hope this letter finds you well. I am writing to serve you with the First Interrogatories and Request for Production of Documents in relation to the ongoing matter [Case Number/Title] pending in [Court Name]. As per the Rules of Civil Procedure in New Mexico, I kindly request your timely response to the following interrogatories and document requests, within [number of days] of receiving this letter. Interrogatories: 1. Please state your full legal name, current address, telephone number, and occupation. 2. Please identify any individuals with knowledge of the facts surrounding [Case Number/Title] and provide their full names, addresses, and telephone numbers. 3. Identify all witnesses you intend to call at trial, providing their full names, addresses, and telephone numbers. 4. Please describe in detail your version of the events leading up to and surrounding [Case Number/Title]. 5. Please identify and provide copies of any written agreements or contracts relevant to [Case Number/Title], including any amendments or modifications. 6. Identify any expert witnesses you intend to call at trial, providing their full names, addresses, areas of expertise, and a summary of their expected testimony. 7. Identify any insurance coverage you hold that may be applicable to [Case Number/Title], including the name of the insurance company and policy number. Request for Production of Documents: 1. Please produce all documents, including contracts, letters, emails, and faxes, relating to [Case Number/Title], from [specific dates or timeframe]. 2. Provide copies of all medical records, invoices, and bills related to any injuries or medical treatment associated with [Case Number/Title]. 3. Produce all photographs, videos, or other visual recordings that depict the scene of the incident and/or your alleged injuries. 4. Provide copies of all relevant financial records, such as tax returns, bank statements, and pay stubs, over the past [specific years or timeframe]. 5. Please provide any insurance policies, including automobile, homeowners, or business policies, that may be applicable to [Case Number/Title]. 6. Produce any written statements, reports, or correspondence from expert witnesses retained or consulted in relation to [Case Number/Title]. Please note that these interrogatories and document requests pertain solely to the matters at hand and are expected to be treated pursuant to the applicable rules and procedures of New Mexico. Failure to timely and fully respond to these interrogatories and document requests may result in appropriate motions being filed with the court to compel discovery. Your timely and comprehensive responses are highly appreciated, as they will facilitate the process of resolving this matter efficiently and fairly. Should you require any clarification or have any concerns regarding these interrogatories and document requests, please do not hesitate to contact my office. Thank you for your attention to this matter, and I look forward to receiving your response by [deadline]. Sincerely, [Your Name] [Your Law Firm, if applicable] [Your Bar Number, if applicable]