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This discovery deficiency letter is a standard form that attorneys can use in a federal court litigation to facilitate a discussion with opposing counsel concerning his or her failure to respond to discovery requests or provision of inadequate, incomplete, or otherwise deficient responses.

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.

Make it a lead-off general objection. Object to anything that is not relevant to the subject matter (no longer the standard) or not likely to lead to admissible evidence (no longer the standard). Don't say if anything is being withheld on the basis of the objection. Use boilerplate wording from form files.

When you respond to a discovery request, you should make sure to do it within the timeframe listed in the discovery request or in the scheduling order if the judge issued one. In some cases, the judge will hold a court conference to establish a timeframe for discovery, motions, and the trial.

For document discovery to be effective, it needs to be well planned.Have a strategy.Adjust the scope of your requests to the questions at issue.Send clear requests.Always consider how your client would be prepared to respond to similar requests.Make your objections clear and specific.

A response is part of the discovery (fact-finding) process that occurs before trial. Certain motions that are filed, such as a request for interrogatories, request for production, or request for admission, require the person served with the motion to file a response within a certain time period.

Objections that may be used in the course of discovery include, but are not limited to the following:Unduly burdensome,Overly broad.Vague.Ambiguous.Disproportional.Protected by the attorney-client privilege.Work product doctrine.

Here are the five steps to introducing discovery responses into evidence:Lodge them with the court. First you need to lodge the requests and responses with the court.Let the court know you want to use them.Designate the portions you'll read.Wait for review and objections.Read the transcript.

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Bronx New York Sample Letter Requesting Answers to Discovery Material

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