Subject: Granting Additional Time to Respond to Defendant's First Set of Interrogatories and First Request for Production of Documents in Cuyahoga, Ohio [Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] [Defendant's Name] [Defendant's Address] [City, State, ZIP] Re: [Case Name/Number] Dear [Defendant's Name], I hope this letter finds you well. I am writing on behalf of [Your Firm/Name], representing [Plaintiff's Name], to discuss the matter of responding to your First Set of Interrogatories and First Request for Production of Documents in the aforementioned case. I would first like to express our appreciation for your cooperation and respect for the legal process thus far. However, due to various circumstances that have affected our workload, we kindly request an extension of time to properly respond to the aforementioned discovery requests. This will enable us to ensure accuracy, gather all relevant information, and provide you with a comprehensive response. Our firm understands the importance of adhering to procedural deadlines, and we are committed to fulfilling our obligations in a timely manner. Therefore, we propose extending the response date from the original time frame outlined in the discovery requests. After a careful assessment of our schedule and the complexity of each request, we believe that a reasonable and fair extension would be [Proposed New Deadline]. This additional time will afford us the opportunity to conduct a thorough review, consult with our client, and gather all required documents and information relevant to your inquiries. We believe that granting this extension would foster a more efficient and productive exchange of information between the parties involved. It is our sincere intention to respond to your discovery requests with accuracy and diligence while maintaining the principles of fairness and transparency. Please consider this letter as a formal request for an extension in the above-mentioned discovery process, and kindly confirm your acceptance of the proposed new deadline. We appreciate your understanding and cooperation in this matter, as it will greatly contribute to the successful resolution of the case at hand. Please do not hesitate to contact me if you have any questions or require any further clarification regarding this request. Thank you for your attention, and we look forward to your prompt response. Yours sincerely, [Your Name] [Your Title/Position] [Your Firm/Name]