Sample Letter to Opposing Counsel regarding Deposition and Subpoena Ducks Cecum in Tennessee Discovery: [Your Name] [Your Law Firm's Name] [Your Address] [City, State, Zip Code] [Date] [Opposing Counsel's Name] [Opposing Counsel's Law Firm's Name] [Opposing Counsel's Address] [City, State, Zip Code] Re: [Case Name] [Case Number] Dear [Opposing Counsel's Name], I hope this letter finds you well. I am writing to discuss the upcoming deposition and to request the production of documents through a subpoena duces tecum in accordance with the Tennessee Discovery rules. 1. Deposition Details: Date: [Proposed Deposition Date] Time: [Proposed Deposition Time] Location: [Proposed Deposition Location] 2. Deposing Party: [Your Client's Name] 3. Deposed Party: [Opposing Party's Name] 4. Purpose of the Deposition: We intend to gather sworn testimony from [Opposing Party's Name] to explore the factual details, circumstances, and potential evidence related to the claims and defenses in this case. The information obtained at the deposition will aid in assessing the merits of each side's arguments and facilitate a fair resolution. 5. Potential Topics to be Covered: a. [Specific Topic 1] b. [Specific Topic 2] c. [Specific Topic 3] 6. Subpoena Ducks Cecum Details: We request that you produce the documents listed below on or before [X number of days] from the date of this letter: a. [Document Request 1] b. [Document Request 2] c. [Document Request 3] 7. Confidentiality: We remind you of your ongoing duty to protect confidential and privileged information. We expect that any documents produced in response to the subpoena duces tecum will be treated as confidential and will not be disclosed to any unauthorized third parties. 8. Objections and Privilege Logs: Should your client object to any document request, please provide a specific objection for each item along with a privilege log if applicable. Failure to object or provide a privilege log may be viewed as a waiver of any objections to the requests. 9. Deposition Protocol: Please inform us regarding any restrictions or guidelines we should adhere to during the deposition. Additionally, if you need any changes to the proposed deposition date, time, or location, please let us know as soon as possible for us to consider. 10. Conclusion: We trust that you will cooperate fully with our requested deposition and promptly produce the outlined documents. If you have any concerns or need clarification on any matter, please do not hesitate to contact me at [Your Phone Number] or [Your Email Address]. Thank you for your attention to this matter. We look forward to conducting a productive and efficient deposition in accordance with Tennessee's discovery rules. Sincerely, [Your Name] [Your Law Firm's Name] [Your Contact Information] Potential variations of Tennessee Discovery — Sample Letter to Opposing Counsel regarding Deposition and Subpoena Ducks Cecum could include: — Sample Letter to Opposing Counsel regarding Subpoena Ducks Cecum Only — Sample Letter to Opposing Counsel regarding Deposition Only — Sample Letter to Opposing Counsel regarding Deposition and Subpoena Ducks Cecum for Expert Witnesses — Sample Letter to Opposing Counsel regarding Deposition and Subpoena Ducks Cecum for Non-Party Witnesses — Sample Letter to Opposing Counsel regarding Deposition and Subpoena Ducks Cecum in Family Law Cases — Sample Letter to Opposing Counsel regarding Deposition and Subpoena Ducks Cecum in Personal Injury Cases