Dear [Defendant's Name], RE: Additional Time to Respond to Defendant's First Set of Interrogatories and First Request for Production of Documents I hope this letter finds you well. I am writing on behalf of [Your Name/Your Law Firm] regarding the above-mentioned matter. We have received your Defendant's First Set of Interrogatories and First Request for Production of Documents dated [Date Received]. Upon careful review and consideration of the content and scope of the interrogatories and document requests, we would like to request for additional time to prepare and submit our responses. Due to the complex nature of the case and the voluminous amount of requested documents, we require an extension to ensure a comprehensive and accurate response. In accordance with the applicable rules of civil procedure and in the interest of promoting efficient litigation and cooperation, we kindly ask for an additional [number of days] beyond the original deadline of [original deadline date], thus setting the new deadline for our responses to [new deadline date]. This extension will provide us with adequate time to thoroughly review the interrogatories and compile the requested documents. We assure you that we are diligently working to gather the necessary information and materials required to respond to your requests. We understand the importance of providing timely and complete responses to facilitate a fair and just resolution to this case. Should the need arise, we are open to discussing a reasonable modification to the proposed deadline, should it be necessary for both parties to engage in further discussions or negotiations regarding certain requests. Our intention is to maintain open lines of communication and foster a cooperative relationship during the discovery process. We kindly request that you acknowledge receipt of this letter and confirm your agreement to the extension of time. Please reply in writing or via email no later than [date] to notify us of your position regarding this matter. Thank you for your understanding and cooperation. We look forward to your prompt response. Sincerely, [Your Name/Your Law Firm] [Your Contact Information]