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 Client Name], the Plaintiff in the above-mentioned case, to request an extension for responding to your first set of interrogatories and request for production of documents. As you are aware, these discovery requests are crucial in gathering necessary information and evidence for the litigation process. We have thoroughly reviewed your interrogatories and request for production of documents, and in order to provide comprehensive responses and ensure accuracy, we kindly request an additional [number of days] for our response. Our client's legal team is currently engaged in extensive research and analysis to gather all pertinent documents and information required. Given the complex nature of the case and the volume of material involved, an extension would greatly assist in providing thorough and accurate responses. I assure you that we are committed to promptly and diligently completing our responses within the requested extension period. By doing so, we aim to facilitate a smooth and efficient legal process for both parties involved and adhere to our duties under the applicable rules of civil procedure. We kindly request your consent to extend the response deadline to [new deadline]. This additional time will enable us to thoroughly review and analyze the information and documents in order to provide complete and accurate responses. If you have any concerns or questions regarding this request, please do not hesitate to contact me at [your contact information]. I remain open to discussing alternative solutions that may be mutually beneficial to ensure the fair progression of this case. Thank you for your time and consideration. We appreciate your cooperation in this matter and look forward to a productive exchange of information. Sincerely, [Your Name] [Your Title/Position] [Your Firm/Organization Name]