Subject: West Virginia Discovery — Sample Letter to Opposing Counsel: Deposition and Subpoena Ducks Cecum Dear [Opposing Counsel's Name], I hope this letter finds you well. I am writing to you today on behalf of my client, [Client's Name], to discuss the forthcoming deposition and subpoena duces tecum. As you are aware, the discovery phase plays a crucial role in our legal proceedings, and it is imperative that we collaborate effectively and ensure the smooth flow of information. 1. Deposition: We kindly request that you provide us with a suitable date, time, and location for the deposition. It is important for all parties involved to accommodate mutually agreeable schedules to maximize efficiency and cooperation. We value your consideration in selecting a convenient location that helps facilitate the process. When assembling your witness list, please include the name, address, and any relevant contact information of the individual(s) who will be deposed. This allows us to prepare appropriately and review the witness's background in advance to expedite the proceedings. 2. Subpoena Ducks Cecum: In accordance with the West Virginia Rules of Civil Procedure, we plan to issue a subpoena duces tecum. This subpoena will require the production of certain documents and records within your control that are relevant to the case [Case Name/Caption]. Enclosed with this letter, you will find a sample subpoena duces tecum that outlines the specific documents we seek. The documents requested may include but are not limited to the following: — Correspondence, letters, emails, and faxes related to [specific subject] — Contracts, agreements, or lease agreements involving [parties involved] — Financial records, such as account statements, balance sheets, and profit/loss statements — Employment records, including personnel files and records of termination, if applicable — Surveillance footage, photographs, or videos relevant to the case — Any other documents that you believe may be relevant to the matter at hand Kindly ensure that the designated custodian of records is aware of the subpoena. We also kindly request that you provide a written verification of the document's authenticity to maintain clear and transparent communication throughout this process. If there are any objections or concerns regarding the scope or relevance of the requested documents, we encourage open dialogue in order to address these matters promptly. It is our shared duty to cooperate, within reason, to ensure a fair and just outcome. We request that you respond to this letter within [reasonable time frame] to confirm the deposition date and to acknowledge receipt of the subpoena. Your timely cooperation is greatly appreciated. Should you have any questions or require further clarification, please do not hesitate to contact me directly at [Your Contact Information]. I look forward to working together towards a smooth discovery process. Thank you for your attention to this matter. Sincerely, [Your Name] [Your Law Firm/Organization] [Address] [Phone Number] [Email Address] Enclosure: Sample Subpoena Ducks Cecum
West Virginia Discovery - Sample Letter to Opposing Counsel regarding Deposition and Subpoena Duces Tecum
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