West Virginia Sample Letter for Plaintiff's Motion for Protective Order, Motion to Quash, Objection to Notice of Deposition Duces Tecum

• Category: Letters - Legal - Documents
• State: Multi-State
• Control #: US-0892LTR
• Format: Word; Rich Text

Description

This form is a sample letter in Word format covering the subject matter of the title of the form. Sample Letter for Plaintiff's Motion for Protective Order, Motion to Quash, Objection to Notice of Deposition Ducks Cecum in West Virginia [Your Name] [Your Address] [City, State, ZIP] [Date] [Recipient's Name] [Recipient's Address] [City, State, ZIP] Re: Motion for Protective Order, Motion to Quash, Objection to Notice of Deposition Ducks Cecum Dear [Recipient's Name], I hope this letter finds you well. I am writing to formally request a protective order, motion to quash, and objection to the notice of deposition duces tecum that was served upon me in relation to [case name and number] pending in the [court name] in West Virginia. I have carefully reviewed the aforementioned notice of deposition duces tecum, and I believe it poses significant burdens, undue harassment, and seeks irrelevant information that is not reasonably calculated to lead to admissible evidence in this case. Therefore, I respectfully request the court to grant the following relief: 1. Motion for Protective Order: I respectfully motion for the issuance of a protective order to prevent the deposition duces tecum from proceeding. This order will safeguard me from unnecessary and intrusive inquiries, protect confidential information that does not relate to the subject of this case, and prevent the deposition from becoming an unwarranted fishing expedition. 2. Motion to Quash: I move to quash the notice of deposition duces tecum on the grounds that it is overly burdensome, oppressive, and violates the principles of proportionality as outlined in Rule [cite the relevant West Virginia Rule of Civil Procedure]. The requested documents go beyond the permissible scope of discovery and are not reasonably calculated to lead to the discovery of admissible evidence. 3. Objection to Notice of Deposition Ducks Cecum: I respectfully object to the notice of deposition duces tecum on the grounds that it requests documents that are privileged, protected by attorney-client privilege, work product doctrine, or any other recognized privilege or protection. Therefore, I assert my right to withhold such privileged documents and to not produce them during the deposition. Furthermore, I would like to bring to your attention that pursuant to [cite the relevant West Virginia Rule of Civil Procedure], the party issuing a deposition subpoena must bear the reasonable costs incurred by the responding party. Therefore, I request reimbursement for any reasonable attorney's fees, costs, and expenses incurred as a result of responding to this burdensome deposition request. I kindly request your prompt attention to this matter and a timely response. In the event that we are unable to resolve this issue amicably, I will be prepared to seek proper relief from the court. Thank you for your understanding and cooperation in this matter. I look forward to your timely response. Sincerely, [Your Name] [Your Contact Information]

Sample Letter for Plaintiff's Motion for Protective Order, Motion to Quash, Objection to Notice of Deposition Ducks Cecum in West Virginia [Your Name] [Your Address] [City, State, ZIP] [Date] [Recipient's Name] [Recipient's Address] [City, State, ZIP] Re: Motion for Protective Order, Motion to Quash, Objection to Notice of Deposition Ducks Cecum Dear [Recipient's Name], I hope this letter finds you well. I am writing to formally request a protective order, motion to quash, and objection to the notice of deposition duces tecum that was served upon me in relation to [case name and number] pending in the [court name] in West Virginia. I have carefully reviewed the aforementioned notice of deposition duces tecum, and I believe it poses significant burdens, undue harassment, and seeks irrelevant information that is not reasonably calculated to lead to admissible evidence in this case. Therefore, I respectfully request the court to grant the following relief: 1. Motion for Protective Order: I respectfully motion for the issuance of a protective order to prevent the deposition duces tecum from proceeding. This order will safeguard me from unnecessary and intrusive inquiries, protect confidential information that does not relate to the subject of this case, and prevent the deposition from becoming an unwarranted fishing expedition. 2. Motion to Quash: I move to quash the notice of deposition duces tecum on the grounds that it is overly burdensome, oppressive, and violates the principles of proportionality as outlined in Rule [cite the relevant West Virginia Rule of Civil Procedure]. The requested documents go beyond the permissible scope of discovery and are not reasonably calculated to lead to the discovery of admissible evidence. 3. Objection to Notice of Deposition Ducks Cecum: I respectfully object to the notice of deposition duces tecum on the grounds that it requests documents that are privileged, protected by attorney-client privilege, work product doctrine, or any other recognized privilege or protection. Therefore, I assert my right to withhold such privileged documents and to not produce them during the deposition. Furthermore, I would like to bring to your attention that pursuant to [cite the relevant West Virginia Rule of Civil Procedure], the party issuing a deposition subpoena must bear the reasonable costs incurred by the responding party. Therefore, I request reimbursement for any reasonable attorney's fees, costs, and expenses incurred as a result of responding to this burdensome deposition request. I kindly request your prompt attention to this matter and a timely response. In the event that we are unable to resolve this issue amicably, I will be prepared to seek proper relief from the court. Thank you for your understanding and cooperation in this matter. I look forward to your timely response. Sincerely, [Your Name] [Your Contact Information]