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A sample letter alerting opposing counsel in a Texas case to perceived deficiencies in their discovery responses or deposition testimony and requesting additional discovery materials to remedy the deficiencies.
Summary. This discovery deficiency letter is a standard form that attorneys can use in a federal court litigation to facilitate a discussion with opposing counsel concerning his or her failure to respond to discovery requests or provision of inadequate, incomplete, or otherwise deficient responses.
In responding to Requests for Production of documents you have three response choices (1) agree to produce (C.C.P. §2031.220); (2) state that after a diligent search and a reasonable inquiry you have no documents (C.C.P. §2031.230) or (3) object (C.C.P. §2031.240).
Answer. Requests for the Production of Documents. 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.
If the other person did not respond or didn't provide complete responses, try to work it out with them directly first. If that does not work, you can request a court order that requires them to respond or respond with more information. You have 45 days to do this.
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.
A deficiency letter is a letter that is issued by the Securities and Exchange Commission (SEC) and indicates a significant deficiency or omission in a registration statement or prospectus.
An SEC "deficiency letter" indicates that there is not adequate disclosure in the registration documents to allow investors to make an informed decision. The deficiency must be cured before the SEC will allow the registration to be effective.