[Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] [Defendant's Name] [Defendant's Address] [City, State, ZIP] Re: Additional Time to Respond to Defendant's First Set of Interrogatories and First Request for Production of Documents Dear [Defendant's Name], I hope this letter finds you well. I am writing on behalf of [Your Company/Organization] in response to your First Set of Interrogatories and First Request for Production of Documents dated [Date]. We appreciate your diligence in initiating the discovery process and are committed to providing you with the requested information as promptly and thoroughly as possible. However, due to the substantial volume of documents involved and the complexity of the case, we kindly request an extension of [number of days] days to respond to your interrogatories and production requests. We understand the significance of this information and acknowledge our responsibility to furnish it within a reasonable timeframe. Our aim is to ensure a comprehensive and accurate response that aligns with our legal obligations. The requested additional time will allow us to carefully examine and evaluate the materials requested, consult with relevant personnel, and assemble the necessary documentation for a complete and accurate response. We assure you that this extension is not sought as a delay tactic, but rather to ensure a thorough and accurate production that will facilitate a fair and impartial resolution of this matter. In the spirit of cooperation, we are committed to providing you with a complete response on or before [new response deadline]. Please note that we will work diligently to ensure our compliance with this revised timeline and will keep you informed of any unforeseen circumstances that may arise. If you have any questions or concerns regarding this request or need additional information, please do not hesitate to contact me at [Phone Number] or [Email Address]. We are open to discussing any potential alternatives or modifications to accommodate both parties' needs. We appreciate your understanding and cooperation in granting us this additional time to respond. Thank you for your patience in this matter, and we look forward to providing you with the requested information within the revised timeframe. Yours sincerely, [Your Name] [Your Title] [Your Company/Organization Name]
Texas Sample Letter Confirming Additional Time to Respond to Defendant's First Set of Interrogatories and First Request for Production of Documents
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FAQ
The discovery rule is a ?narrow exception? to the legal injury rule that ?defers accrual of a cause of action until the plaintiff knew or, exercising reasonable diligence, should have known of the facts giving rise to the cause of action.? Berry, 646 S.W.
(B) In a suit governed by the Family Code, all discovery must be conducted during the discovery period, which begins when the suit is filed and continues until 180 days after the date the first request for discovery of any kind is served on a party.
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.
The responding party must serve a written response on the requesting party within 30 days after service of the interrogatories, except that a defendant in a suit governed by the Family Code served with a request before the defendant's answer is due need not respond until 50 days after service of the request.
Generally, the party receiving the discovery request has 30 days to respond. Some exceptions and variations apply, so make sure you review how much time you have to respond depending on the type of case, the rules, and the type of discovery method used.
In a county or district court, the defendant must answer ?on or before a.m. on the Monday next after the expiration of 20 days after the date of service thereof.? Tex. R.
They are provided for your information. There is no form for your answer, but you typically have to respond in a specified format, using paper with numbers down the left-hand side, with your name and address at the top left, the name of the court and of the case, and the case number.
Your answers to the interrogatories should usually be short, clear, and direct and should answer only the question that is being asked. This is not the time to set out your entire case or defense to the other side. Take the time to make sure your answers are correct and truthful.
