Dear [Opposing Party's Name], RE: PLAINTIFF'S MOTION TO COMPEL PRODUCTION OF THE DOCUMENTS REQUESTED IN PLAINTIFF'S SECOND REQUEST FOR PRODUCTION OF DOCUMENTS I hope this letter finds you in good health and spirits. I am writing to bring your attention to the outstanding production of documents in response to Plaintiff's Second Request for Production of Documents in the above-mentioned case. The purpose of this letter is to formally request the immediate production of the documents, as specified in the Plaintiff's Second Request for Production of Documents. Despite the initial deadline for production having passed, we have yet to receive a substantial response or any indication of your willingness to produce the requested documents. To give you a clear understanding of the scope of the request, and to facilitate a timely response, we have provided a detailed description of the documents sought and their relevance to the case: 1. [Specify Document]: This document pertains to [describe relevance and why it is crucial for establishing the facts of the case]. 2. [Specify Document]: This document is crucial for [describe relevance, e.g., assessing damages, determining liability, etc.]. 3. [Specify Document]: This document is necessary for [describe relevance, e.g., evaluating the credibility of key witnesses, establishing the timeline of events, etc.]. 4. [Specify Document]: This document is relevant to [describe relevance, e.g., evaluating the defendant's intent, proving negligence, etc.]. Based on the importance and relevance of these requested documents, we kindly request that you promptly produce them without further delay. It is essential to ensure a fair and expedient resolution of this case. Furthermore, we remind you that under [state applicable rules or statutes, e.g., Rule 34 of the Puerto Rico Rules of Civil Procedure], the failure to respond adequately to a request for production of documents may result in sanctions, including but not limited to, the Court's granting of a motion to compel and awarding attorney's fees and costs. In light of the aforementioned circumstances, we respectfully request that you produce the requested documents within [specify a reasonable timeframe, considering the complexity of the request]. Please also confirm receipt of this letter and provide a specific date by which we can expect the documents to be delivered. Should you require any clarification or have any concerns regarding the production of documents, please do not hesitate to contact me at [your contact information]. We remain open to discussing the possibility of a reasonable extension if time constraints or other valid reasons necessitate such an arrangement. Thank you for your attention to this matter, and we look forward to your prompt cooperation in resolving this outstanding issue. Sincerely, [Your Name] [Your Law Firm Name] [Your Contact Information]
Puerto Rico 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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How to fill out 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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FAQ
The process of delivering, or making available for review, documents in response to a request for documents, such as a request for production and a subpoena. A request for documents may call for the production of paper (hard copy) documents and electronically stored information (ESI).
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 ...
How to Request Production of Documents and Things Download the template for Request for Production. ... Fill out basic information at the top. ... Choose a location for the other side to bring the documents. ... Add your own definitions (if useful) ... Write your requests for production. ... Sign and date the document. ... Make copies.
A Request for Production (also known as a Demand for Inspection) asks the other side to produce and allow copying or inspection and measuring of a document or thing.
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.
Generally, a request for production asks the responding party to make available the original documents, but a requesting party may permit photocopies of the requested documents be sent instead, if inspection of the original document is not necessary.
A Motion to Compel is a formal request to the Court to require a party or a non-party in a lawsuit to comply with a discovery request such as a request for production, request for admission, interrogatory, or subpoena.
Your response to a request for production consists of two parts: One part is a written response to the requests, in which you state under penalty of perjury that you will produce the requested items; that you will not produce and why; or that you object to a request on legal grounds.
