[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]