New Mexico 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. [Your Name] [Your Address] [City, State, Zip] [Email Address] [Phone Number] [Date] [Opposing Party's Name] [Opposing Party's Address] [City, State, Zip] Re: Plaintiff's Motion for Protective Order, Motion to Quash, Objection to Notice of Deposition Ducks Cecum Dear [Opposing Party's Name], I hope this letter finds you well. I am writing to bring to your attention the important matter of the upcoming deposition duces tecum and to formally request a protective order, motion to quash, and to register our objection to the notice of deposition duces tecum, filed by your office on [date]. As you are aware, the State of New Mexico affords certain rights to both plaintiffs and defendants during the discovery process. It is crucial to adhere to these rules to ensure a fair and just legal proceeding. We believe that your notice of deposition duces tecum fails to comply with these regulations, thus necessitating our motion to quash. The deposition duces tecum notice, which seeks the production of documents and evidence, may be overly burdensome, vague, and unduly intrusive without a specific foundation or relevance to the case at hand. Therefore, we respectfully request a protective order to prevent the disclosure of any documents or information that may be confidential, privileged, or irrelevant to this ongoing litigation. Additionally, we argue that the notice of deposition duces tecum exceeds the scope and allowable limitations under the New Mexico Rules of Civil Procedure. We believe that the requested documents, as presented within the notice, are not reasonably calculated to lead to the discovery of admissible evidence. Therefore, we hereby move to quash the notice of deposition duces tecum in its entirety. In light of the aforementioned reasons, we respectfully request that you withdraw the current notice of deposition duces tecum and, instead, provide a revised and narrowed notice that conforms to the rules and limitations set forth by the State of New Mexico. We hope for your prompt attention and cooperation concerning this matter. If we do not receive a satisfactory response within [a reasonable timeframe, for example, ten (10) days], we reserve the right to seek appropriate legal remedies and relief available under the New Mexico Rules of Civil Procedure. Thank you for your attention to this matter. We look forward to your prompt response. Yours sincerely, [Your Name] [Your Law Firm's Name] (if applicable) [Your Law Firm's Address] (if applicable) [City, State, Zip] (if applicable) [Email Address] [Phone Number]

[Your Name] [Your Address] [City, State, Zip] [Email Address] [Phone Number] [Date] [Opposing Party's Name] [Opposing Party's Address] [City, State, Zip] Re: Plaintiff's Motion for Protective Order, Motion to Quash, Objection to Notice of Deposition Ducks Cecum Dear [Opposing Party's Name], I hope this letter finds you well. I am writing to bring to your attention the important matter of the upcoming deposition duces tecum and to formally request a protective order, motion to quash, and to register our objection to the notice of deposition duces tecum, filed by your office on [date]. As you are aware, the State of New Mexico affords certain rights to both plaintiffs and defendants during the discovery process. It is crucial to adhere to these rules to ensure a fair and just legal proceeding. We believe that your notice of deposition duces tecum fails to comply with these regulations, thus necessitating our motion to quash. The deposition duces tecum notice, which seeks the production of documents and evidence, may be overly burdensome, vague, and unduly intrusive without a specific foundation or relevance to the case at hand. Therefore, we respectfully request a protective order to prevent the disclosure of any documents or information that may be confidential, privileged, or irrelevant to this ongoing litigation. Additionally, we argue that the notice of deposition duces tecum exceeds the scope and allowable limitations under the New Mexico Rules of Civil Procedure. We believe that the requested documents, as presented within the notice, are not reasonably calculated to lead to the discovery of admissible evidence. Therefore, we hereby move to quash the notice of deposition duces tecum in its entirety. In light of the aforementioned reasons, we respectfully request that you withdraw the current notice of deposition duces tecum and, instead, provide a revised and narrowed notice that conforms to the rules and limitations set forth by the State of New Mexico. We hope for your prompt attention and cooperation concerning this matter. If we do not receive a satisfactory response within [a reasonable timeframe, for example, ten (10) days], we reserve the right to seek appropriate legal remedies and relief available under the New Mexico Rules of Civil Procedure. Thank you for your attention to this matter. We look forward to your prompt response. Yours sincerely, [Your Name] [Your Law Firm's Name] (if applicable) [Your Law Firm's Address] (if applicable) [City, State, Zip] (if applicable) [Email Address] [Phone Number]