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] Re: Case No. [Case Number] Plaintiff's Motion to Compel Answers to Plaintiff's Second Set of Interrogatories Dear [Opposing Party’s Name], I hope this letter finds you well. I am writing to discuss the outstanding responses to the Plaintiff's Second Set of Interrogatories that were served upon you on [Date]. It has come to my attention that we have not received your responses within the time prescribed by the New Mexico Rules of Civil Procedure. Consequently, I am left with no choice but to file this Motion to Compel Answers to Plaintiff's Second Set of Interrogatories. Background of the Case: [Provide a brief overview of the case, including relevant facts, parties involved, and the main legal issues.] Plaintiff's Second Set of Interrogatories: [Describe the specific set of interrogatories that were propounded, their purpose, and their significance in the case.] Non-Compliance with the New Mexico Rules of Civil Procedure: As you know, the New Mexico Rules of Civil Procedure govern the procedural aspects of civil litigation within the state. Specifically, Rule 1-036 NMRA requires that responses to interrogatories be served within 30 days after service of the interrogatories. It is evident that you have failed to comply with these rules as it has been [number of days] since we served the Plaintiff's Second Set of Interrogatories upon you. Importance of Prompt and Complete Responses: The timely and comprehensive provision of interrogatory responses is crucial to the fair determination of this case. By refusing or neglecting to provide the requested answers, you hinder our ability to fully understand the facts, evaluate the strength of our claims, and prepare for trial. Your non-compliance undermines the principles of fairness, efficiency, and justice that form the foundation of the legal system. Relief Sought: In light of your non-compliance with the New Mexico Rules of Civil Procedure, we kindly request that you immediately provide complete responses to the Plaintiff's Second Set of Interrogatories. Our client is entitled to a full and accurate disclosure of the relevant information in a timely manner. We trust that you value the integrity of our legal system and will respect our request. If you do not provide the requested responses within [a reasonable timeframe, usually 10-14 days], we will have no alternative but to file a formal motion with the court seeking an order compelling you to comply, as well as seeking any appropriate sanctions permitted by the court rules and relevant case law. We hope it does not come to that, and we can resolve this matter amicably. Please acknowledge receipt of this letter and confirm in writing the date by which we can anticipate receiving your compliant responses. Should you have any concerns or require an extension of time, please communicate with me as soon as possible. We appreciate your attention to this matter and hope to resolve it swiftly and efficiently. Thank you for your cooperation. Sincerely, [Your Name] [Your Law Firm, if applicable] [Attorney for the Plaintiff]
[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] Re: Case No. [Case Number] Plaintiff's Motion to Compel Answers to Plaintiff's Second Set of Interrogatories Dear [Opposing Party’s Name], I hope this letter finds you well. I am writing to discuss the outstanding responses to the Plaintiff's Second Set of Interrogatories that were served upon you on [Date]. It has come to my attention that we have not received your responses within the time prescribed by the New Mexico Rules of Civil Procedure. Consequently, I am left with no choice but to file this Motion to Compel Answers to Plaintiff's Second Set of Interrogatories. Background of the Case: [Provide a brief overview of the case, including relevant facts, parties involved, and the main legal issues.] Plaintiff's Second Set of Interrogatories: [Describe the specific set of interrogatories that were propounded, their purpose, and their significance in the case.] Non-Compliance with the New Mexico Rules of Civil Procedure: As you know, the New Mexico Rules of Civil Procedure govern the procedural aspects of civil litigation within the state. Specifically, Rule 1-036 NMRA requires that responses to interrogatories be served within 30 days after service of the interrogatories. It is evident that you have failed to comply with these rules as it has been [number of days] since we served the Plaintiff's Second Set of Interrogatories upon you. Importance of Prompt and Complete Responses: The timely and comprehensive provision of interrogatory responses is crucial to the fair determination of this case. By refusing or neglecting to provide the requested answers, you hinder our ability to fully understand the facts, evaluate the strength of our claims, and prepare for trial. Your non-compliance undermines the principles of fairness, efficiency, and justice that form the foundation of the legal system. Relief Sought: In light of your non-compliance with the New Mexico Rules of Civil Procedure, we kindly request that you immediately provide complete responses to the Plaintiff's Second Set of Interrogatories. Our client is entitled to a full and accurate disclosure of the relevant information in a timely manner. We trust that you value the integrity of our legal system and will respect our request. If you do not provide the requested responses within [a reasonable timeframe, usually 10-14 days], we will have no alternative but to file a formal motion with the court seeking an order compelling you to comply, as well as seeking any appropriate sanctions permitted by the court rules and relevant case law. We hope it does not come to that, and we can resolve this matter amicably. Please acknowledge receipt of this letter and confirm in writing the date by which we can anticipate receiving your compliant responses. Should you have any concerns or require an extension of time, please communicate with me as soon as possible. We appreciate your attention to this matter and hope to resolve it swiftly and efficiently. Thank you for your cooperation. Sincerely, [Your Name] [Your Law Firm, if applicable] [Attorney for the Plaintiff]