Dear [Defendant's Name], I hope this letter finds you well. I am writing on behalf of [Plaintiff's Name] in response to your First Set of Interrogatories and First Request for Production of Documents, dated [date]. Firstly, I would like to extend our gratitude for providing us with an opportunity to respond to your interrogatories and requests for production. We understand the importance of timely and accurate information exchange during the legal proceedings and are committed to cooperating fully. Having thoroughly reviewed the extensive nature of your interrogatories and requests for production, we recognize the need for additional time to gather and compile the requested information in a comprehensive manner. To ensure complete and accurate responses, we kindly request an extension of [number of days requested] from the original deadline of [original deadline date] to submit our responses. In consideration of this extension, we assure you that we are diligently working towards obtaining the necessary documents and information. Our legal team is actively engaging with relevant individuals, conducting thorough research, and consulting with experts to provide you with the most accurate and precise responses possible. Additionally, we would like to mention that the time extension will not delay or hinder the progression of the case. We are fully committed to resolving this matter in a timely and fair manner, and we remain dedicated to meeting all the obligations outlined in the legal process. Rest assured, we understand the importance of ensuring a smooth and efficient exchange of information between the parties involved. Thus, we will make every effort to timely provide our responses within the extended timeframe, thereby promoting a transparent and fair legal process. Please acknowledge receipt of this letter and confirm your agreement to grant the requested extension by signing and returning the enclosed copy of this letter no later than [confirmation date requested]. Your cooperation in this matter is greatly appreciated. Thank you for your understanding and cooperation in this regard. Should you have any questions or concerns, please do not hesitate to reach out to me directly at [contact information]. Best regards, [Your Name] [Your Title/Designation] [Your Firm/Organization Name] [Your Contact Information] Enclosure: Sample Letter Confirming Additional Time to Respond to Defendant's First Set of Interrogatories and First Request for Production of Documents.
Houston Texas Sample Letter Confirming Additional Time to Respond to Defendant's First Set of Interrogatories and First Request for Production of Documents
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FAQ
WITHOUT WAIVING THESE DEFENSES, I RESPOND AS FOLLOWS: I am producing all of the requested documents that exist. I am producing all of the requested documents in my possession. I have requested copies of additional documents and expect to produce them by (date).
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.
The process of delivering, or making available for review, documents produced during litigation or in response to a request for documents from a regulatory or other body. Discoverable documents in litigation may include both paper (hard copy) documents and electronically stored information (ESI).
Answer. Requests for the Production of Documents. Definition: A written list of documents, electronic files, and audio and video recordings or physical things, submitted to a party from his or her adversary to inspect and copy the requested items and that have relevance to the issues in a lawsuit.
Retain a photocopy of your written response and the original signed proof of service for your records. You do not need to file your response or proof of service with the court. If the other party claims you did not respond, you may use these documents to defend yourself against a Motion to Compel.
A. Blanket, unsupported objections that a discovery request is ?vague, overly broad, or unduly burdensome? are, by themselves, meaningless, and disregarded by the Court. A party objecting on these bases must explain the specific and particular ways in which a request is vague, overly broad, or unduly burdensome.
The process of delivering, or making available for review, documents in response to a request for documents, such as a request for production and a subpoena. A request for documents may call for the production of paper (hard copy) documents and electronically stored information (ESI).
Step 1: Complete Your Written Responses. There is no Judicial Council form specifically for this procedure.Step 2: Make Copies.Step 3: Have Your Response Served.Step 4: Retain Your Response and Proof of Service.Step 5: Produce the Requested Documents and Things.
If you are on the receiving end of an RFI, here are some good pointers on how to respond. Don't be afraid to ask questions. If there is any part in the RFI that is unclear or ambiguous, don't be afraid to seek clarification from the sender.Promptly deal with an incoming RFI.Respond as accurately as you can.
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.
