[Your Name] [Your Address] [City, State, ZIP] [Email Address] [Date] [Opposing Party's Attorney] [Attorney's Firm] [Address] [City, State, ZIP] Subject: Review of Answers and Objections to Plaintiff's 2nd Set of Interrogatories Dear [Opposing Party's Attorney], I hope this letter finds you well. I am writing on behalf of my client, [Your Name/Your Client's Name], in response to your submission of the Answers and Objections to Plaintiff's 2nd Set of Interrogatories in the above-mentioned case. Firstly, I would like to express our appreciation for providing the requested responses within the specified timeline. However, upon a thorough review of the answers and objections provided, we have identified certain concerns and discrepancies that require clarification and resolution. This letter serves as a formal request for review and further response as necessary. 1. General Objections: a. Lacks Specificity: Your objections frequently lack specificity, making it difficult for us to understand the basis for the objection. We kindly request you to provide more detailed explanations to clarify the grounds for your general objections. b. Unduly Burdensome: We believe your claim of undue burden in responding to certain interrogatories is unfounded. It is essential to reconsider whether your objections on this ground are valid in relation to the specific questions asked. c. Vague and Ambiguous: Many of your objections appear vague and ambiguous, hindering us in understanding your intended meaning. We kindly ask you to revise and provide clearer objections to facilitate efficient communication and resolution. 2. Specific Objections: a. Objection to Relevance: While we acknowledge that relevance objections are permissible, we disagree with several objections on this basis. We request that you review the questions carefully and provide a more targeted response, explaining the specific reasons for your objections. b. Privilege Objections: We have noted that certain privilege objections have been raised in response to interrogatories. We urge you to identify the specific privilege(s) invoked and provide a privilege log, as required by the applicable rules of civil procedure. c. Over breadth Objections: Several over breadth objections have been raised without sufficient explanation. We kindly request you to reconsider these objections and provide focused responses to the interrogatories, ensuring compliance with the relevant regulations. We anticipate your prompt attention to our concerns and request for clarification. Please be advised that in the absence of a timely response or resolution, we may seek appropriate remedies available under the law to address these deficiencies. To facilitate further discussion and resolution, we suggest a meet-and-confer session or a teleconference between the parties involved. This will help us address any outstanding issues, reduce unnecessary litigation, and promote a more efficient resolution of the matter. Thank you for your cooperation in this matter. We look forward to receiving your revised responses and further engaging in a productive dialogue. Yours sincerely, [Your Name] [Your Title] [Your Law Firm Name]