Title: Rhode Island Discovery — Sample Letter to Opposing Counsel regarding Deposition and Subpoena Ducks Cecum Dear [Opposing Counsel's Name], I am writing to you on behalf of [Your Client's Name] in regard to the pending case [Case Number] in the [Rhode Island] court. Our purpose is to request your cooperation for the deposition of [Witness's Name] and the production of documents through a subpoena duces tecum. 1. Introduction: In this section, you introduce yourself as the representative counsel for your client and provide a brief background of the case. Include relevant case details such as the court and case number, making sure to emphasize the jurisdiction of Rhode Island. 2. Deposition Request: Clearly state your client's intention to depose [Witness's Name]. Mention the importance of obtaining crucial information and testimony from the witness under oath, which will aid in uncovering relevant evidence and clarifying the facts of the case. 3. Deposition Scheduling: Specify multiple potential dates and times for the deposition, along with the address of the location where the deposition will take place. Offer to coordinate with the opposing counsel to determine a mutually convenient date and location for the proceeding. 4. Subpoena Ducks Cecum: Explain the necessity of a subpoena duces tecum in order to procure essential documents and records relevant to the case. Clarify the types of records you are seeking, such as medical records, financial documents, or any other evidence specific to your case. Emphasize that the documents requested are essential for a fair resolution of the case. 5. Production of Documents: Detail the date by which the requested documents need to be produced and the format in which they should be delivered (electronically or physical copies). Specify any limitations or requests regarding the redaction of sensitive or confidential information to comply with privacy laws. 6. Collaboration and Cooperation: Express the hope and expectation for cooperation between both parties in facilitating a smooth deposition process and adhering to the timelines set forth. Encourage open communication and the potential for an amicable resolution throughout the discovery process. 7. Closing Remarks: Conclude your letter by restating your appreciation for the opposing counsel's cooperation and willingness to comply with the deposition and subpoena requests. Mention that failure to comply within the requested timeframe may result in further legal action to safeguard your client's rights. Types of Rhode Island Discovery — Sample Letters to Opposing Counsel regarding Deposition and Subpoena Ducks Cecum: — Pre-Trial Communication: A letter sent during the initial stages of the case to formally request a deposition and subpoena duces tecum. — Motion to Compel Compliance: If the opposing counsel fails to respond or comply with the deposition and subpoena requests, a motion to compel compliance can be prepared to present before the court seeking judicial assistance in enforcing discovery requests. Remember to adapt the sample letter to your specific case and consult with legal professionals to ensure compliance with Rhode Island's specific discovery rules and procedures. Sincerely, [Your Name] [Your Law Firm] [Contact Information]