[Your Name] [Your Address] [City, State, ZIP Code] [Email Address] [Phone Number] [Date] [Defendant's Name or Attorney's Name] [Defendant's Law Firm] [Address] [City, State, ZIP Code] Subject: Confirmation of Additional Time to Respond to Defendant's First Set of Interrogatories and First Request for Production of Documents Dear [Defendant's Name or Attorney's Name], I hope this letter finds you well. I am writing on behalf of [Your Name/Your Law Firm] to request an extension for responding to the Defendant's First Set of Interrogatories and First Request for Production of Documents, as per the recently received documents. First and foremost, we appreciate the cooperation demonstrated by your office in providing us with the aforementioned discovery requests. In order to ensure a thorough and comprehensive response, we kindly ask for an extension of [number of days requested, e.g., 30 days] from the original due date, which was [original due date, e.g., June 15, 20XX]. The complexities and sheer volume of the discovery requests necessitate additional time for our legal team to identify, gather, analyze, and prepare the requested information and documents. It is crucial for us to present accurate and concise responses to ensure a fair and just legal process. We assure you that we are dedicated to fulfilling our obligations within the extended timeframe and will make every effort to deliver a complete and detailed response. By granting this extension, we believe it will facilitate a more efficient exchange of information and uphold the principles of fairness in this case. Additionally, we are cognizant of the importance of timely communication throughout the legal process. To this end, we pledge to keep you informed of our progress and anticipate providing you with initial updates on our response by [proposed update date, e.g., July 5, 20XX]. To make the process more manageable and organized, we propose that the parties mutually agree to adjust any upcoming deadlines or hearing dates to accommodate this extended time frame. Once again, we sincerely appreciate your understanding and cooperation in this matter. Please confirm your agreement to the extension by signing and returning a copy of this letter to our office using the enclosed self-addressed stamped envelope. Should you have any questions, please do not hesitate to contact me at [your phone number] or [your email address]. Thank you for your attention to this matter, and we look forward to a successful resolution. Yours sincerely, [Your Name] [Your Law Firm] [Enclosure: Copy of this letter] CC: [Plaintiff's Attorney's Name]
Oakland Michigan 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
How to present a losing objection: 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.
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.
What Is a Request for Production of Documents? A request for production is a discovery device used to gain access to documents, electronic data, and physical items held by an opposing party in a legal matter. The aim is to gain insight into any relevant evidence that the opposing party holds.
Your response to a request for production consists of two parts: One part is a written response to the requests, in which you state under penalty of perjury that you will produce the requested items; that you will not produce and why; or that you object to a request on legal grounds.
If a request asks for a document, make a copy of the document; in your response, describe the document and say that a copy is attached; and attach a copy of the document to the responses you send back to the other side.
If you are unable to answer a specific question because you don't know or don't have access to the appropriate information, you must indicate the reasons. You may refer to a previous response when responding to an interrogatory providing the previous response sufficiently answers the later interrogatory.
Step 1: Carefully Review All the Requests. Review each request to ensure you fully understand the question, and can answer it completely.Step 2: Complete Your Responses to the Interrogatories.Step 3: Make Photocopies.Step 4: Have Your Responses Served.Step 5: Retain Your Documents.
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.
A good faith attempt is more than arguing with opposing counsel. Instead, the law requires you to discuss the issues, compare views, exchange information (including statutes and case law supporting your position), and propose solutions to discovery fights without court interference.
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).
