Sample Letter for Plaintiff's Motion to Compel the Production of the Documents Requested in Plaintiff's Second Request for Production of Documents: [Your Name] [Your Address] [City, State, ZIP Code] [Email Address] [Phone Number] [Date] [Recipient's Name] [Recipient's Address] [City, State, ZIP Code] Subject: Plaintiff's Motion to Compel the Production of Requested Documents Dear [Recipient's Name], I hope this letter finds you well. I am writing as the plaintiff in the above-mentioned case to request, pursuant to [relevant law or rule], the immediate production of the documents requested in the Plaintiff's Second Request for Production of Documents. As you are aware, on [date], I served the Second Request for Production of Documents upon you. The request sought relevant and material documents related to [provide specific details of the documents requested]. However, to date, I have not received any acknowledgment or production of the requested documents. The production of these documents is crucial to the fair resolution of this case and to maintain the transparency and integrity of the legal process. As a diligent and responsible party to this lawsuit, I have diligently followed all procedures, adhered to all timelines, and promptly responded to all the requests made by your side. However, it is disappointing that despite these efforts, the requested documents have not been produced or even acknowledged. This lack of cooperation hampers the progress of this case and significantly impacts the pursuit of justice. Therefore, pursuant to [relevant law or rule], I hereby move the Court to compel the production of the requested documents within [reasonable time frame] so that I may adequately evaluate the merits of my case and prepare a strong defense. In support of this motion, I have attached a signed copy of the Plaintiff's Second Request for Production of Documents. I urge you to promptly proceed with the production of the requested documents to ensure the smooth and expeditious resolution of this matter. Should you require any clarification regarding the specific items requested or face any difficulties in complying with this motion, I encourage you to contact me immediately to discuss the matter. Please be advised that the failure to comply with this motion may result in appropriate legal action, including but not limited to seeking sanctions and attorney's fees incurred as a result of the motion to compel. Thank you for your prompt attention to this matter. I look forward to receiving the requested documents at the earliest opportunity. If you require any further information, please do not hesitate to contact me. Yours sincerely, [Your Full Name] [Your Case Reference/Number] [Attachments: Plaintiff's Second Request for Production of Documents]
New York Sample Letter for Plaintiff's Motion to Compel the Production of the Documents Requested in Plaintiff's Second Request for Production of Documents
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Grounds For Motion ? A party may move to compel the production of documents or things if the response (1) agrees to comply, but compliance is incomplete, (2) the responding party's indication of inability to comply is incomplete, inadequate, or evasive, or (3) an objection to a request is made that is too general or ...
Any party may serve on any other party a request (1) to produce and permit the party making the request, or someone acting on the requestor's behalf, to inspect and copy, any designated documents (including writings, drawings, graphs, charts, photographs, phonorecords, and other data compilations from which information ...
Definition: A written list of documents, electronic files, and audio and video recordings or physical things, submitted to a party from his or her adversary to inspect and copy the requested items and that have relevance to the issues in a lawsuit.
You can write back to the person making the request and explain why you are objecting. You must have a valid reason to object to giving the other party the documents.
Common objections to requests for admission include: The request is impermissibly compound. The propounding party may ask you to admit only one fact per statement. You may object to any request that asks you to admit two or more different facts in a single request.
Requests for Production or Demands for Inspection require you to produce documents for copying or in some cases actual items for inspection. Responding to the request has 2 parts: State if you can comply with the request (all of it or some of it) or give the reason why you can't comply.
Common objections to requests for production or inspection include: The request is overly broad or unduly burdensome. ... The request is vague, ambiguous, or unintelligible. ... The request is not reasonably calculated to lead to the discovery of relevant, admissible evidence.
I am producing all of the requested documents that exist. I am producing all of the requested documents in my possession. I have requested copies of additional documents and expect to produce them by ___________________________ (date).
