Oregon Discovery - Sample Letter to Opposing Counsel regarding Deposition and Subpoena Duces Tecum

• Category: Letters - Legal - Discovery
• State: Multi-State
• Control #: US-0480LTR
• 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 Law Firm's Name] [Address] [City, State, ZIP Code] [Phone Number] [Email Address] [Date] [Opposing Counsel's Name] [Opposing Counsel's Law Firm's Name] [Address] [City, State, ZIP Code] Re: [Case Title/Number] Dear [Opposing Counsel's Name], I hope this letter finds you well. I am writing to discuss the upcoming deposition and the issuance of a subpoena duces tecum in the aforementioned case. The purpose of this letter is to outline our position on the matter and ensure a smooth and efficient discovery process. 1. Deposition: We hereby propose to conduct the deposition of [Party/Witness Name] on [Date] at [Time], to take place at [Location]. The deposition is expected to last approximately [estimated duration] hours, during which time we intend to examine the deponent on various matters relevant to the case. 2. Subpoena Ducks Cecum: In conjunction with the deposition, we intend to issue a subpoena duces tecum to [Party/Witness Name]. The purpose of this subpoena is to request the production of specific documents and tangible items that are pertinent to the claims and defenses in this case. Our intention is to ensure a comprehensive and thorough exploration of all relevant evidence during the deposition. 3. Scope of the Subpoena: The attached document outlines the specific documents and items we are seeking through the subpoena duces tecum. Please note that the requests are tailored to the issues in dispute and are reasonable in scope. 4. Confidentiality and Protective Order: We believe it is essential to address issues of confidentiality and protection of sensitive information during the discovery process. We propose entering into a stipulated protective order to safeguard any confidential, proprietary, or sensitive information that may be disclosed during the deposition and pursuant to the subpoena. 5. Scheduling and Coordination: To facilitate a mutually agreeable deposition date and streamline the process, we kindly request that you provide us with your available dates and preferred location for the deposition within [number of days] from the date of this letter. Upon receipt of your response, we will coordinate with all parties involved to confirm the final deposition date and location. 6. Court Reporter and Videographer: In order to ensure an accurate record of the deposition, we intend to have a licensed and certified court reporter and videographer present. The cost of these services will be shared between the parties as agreed upon or in accordance with the court's guidelines. We look forward to your prompt response and cooperation in scheduling the deposition and complying with the terms of the subpoena duces tecum. Please feel free to contact me directly at [Phone Number] or [Email Address] should you have any questions or wish to discuss any issues pertaining to this matter. Thank you for your attention to this matter, and we remain hopeful for a productive discovery process. Sincerely, [Your Name] [Your Law Firm's Name]

[Your Name] [Your Law Firm's Name] [Address] [City, State, ZIP Code] [Phone Number] [Email Address] [Date] [Opposing Counsel's Name] [Opposing Counsel's Law Firm's Name] [Address] [City, State, ZIP Code] Re: [Case Title/Number] Dear [Opposing Counsel's Name], I hope this letter finds you well. I am writing to discuss the upcoming deposition and the issuance of a subpoena duces tecum in the aforementioned case. The purpose of this letter is to outline our position on the matter and ensure a smooth and efficient discovery process. 1. Deposition: We hereby propose to conduct the deposition of [Party/Witness Name] on [Date] at [Time], to take place at [Location]. The deposition is expected to last approximately [estimated duration] hours, during which time we intend to examine the deponent on various matters relevant to the case. 2. Subpoena Ducks Cecum: In conjunction with the deposition, we intend to issue a subpoena duces tecum to [Party/Witness Name]. The purpose of this subpoena is to request the production of specific documents and tangible items that are pertinent to the claims and defenses in this case. Our intention is to ensure a comprehensive and thorough exploration of all relevant evidence during the deposition. 3. Scope of the Subpoena: The attached document outlines the specific documents and items we are seeking through the subpoena duces tecum. Please note that the requests are tailored to the issues in dispute and are reasonable in scope. 4. Confidentiality and Protective Order: We believe it is essential to address issues of confidentiality and protection of sensitive information during the discovery process. We propose entering into a stipulated protective order to safeguard any confidential, proprietary, or sensitive information that may be disclosed during the deposition and pursuant to the subpoena. 5. Scheduling and Coordination: To facilitate a mutually agreeable deposition date and streamline the process, we kindly request that you provide us with your available dates and preferred location for the deposition within [number of days] from the date of this letter. Upon receipt of your response, we will coordinate with all parties involved to confirm the final deposition date and location. 6. Court Reporter and Videographer: In order to ensure an accurate record of the deposition, we intend to have a licensed and certified court reporter and videographer present. The cost of these services will be shared between the parties as agreed upon or in accordance with the court's guidelines. We look forward to your prompt response and cooperation in scheduling the deposition and complying with the terms of the subpoena duces tecum. Please feel free to contact me directly at [Phone Number] or [Email Address] should you have any questions or wish to discuss any issues pertaining to this matter. Thank you for your attention to this matter, and we remain hopeful for a productive discovery process. Sincerely, [Your Name] [Your Law Firm's Name]