Sample Letter Confirming Additional Time to Respond to Defendant's First Set of Interrogatories and First Request for Production of Documents — San Jose, California [Your Name] [Your Address] [City, State, Zip Code] [Email Address] [Phone Number] [Date] [Defendant's Name] [Defendant's Address] [City, State, Zip Code] Re: Additional Time to Respond to Defendant's First Set of Interrogatories and First Request for Production of Documents Dear [Defendant's Name], I hope this letter finds you well. I am writing to request additional time to respond to the Defendant's First Set of Interrogatories and First Request for Production of Documents as part of the ongoing litigation process in the San Jose, California jurisdiction. As a professional courtesy, I am seeking an extension of [state number of days or specific date] to adequately review and prepare the necessary responses. Due to the complexity of the case and the extensive nature of the requested documents, it is crucial to ensure a comprehensive and accurate response. Over the course of this case, I have diligently been gathering and organizing the materials necessary for a thorough response. However, due to unforeseen circumstances [provide a brief explanation if applicable, such as conflicting court appearances, illness, or other force majeure events], I need additional time to complete the task with utmost care and diligence. I assure you that my delay in providing the responses is not intended to cause unnecessary delay or prejudice to the case. On the contrary, I recognize the importance of providing timely and accurate information to facilitate the legal proceedings. Requesting this extension will afford me the opportunity to provide a comprehensive response, ultimately benefiting both parties involved in this matter. I kindly request your understanding and cooperation in granting me the additional time. I assure you that I will submit the complete responses to the Defendant's First Set of Interrogatories and First Request for Production of Documents no later than [mention new deadline]. Furthermore, I appreciate your attention to this matter and would be more than willing to discuss any concerns or potential alternatives regarding this extension request. Please do not hesitate to contact me by email or phone [mention preferred method of contact] at your earliest convenience. Thank you for your understanding and cooperation. I look forward to resolving this matter in a fair and efficient manner. Sincerely, [Your Name]
San Jose California 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
A party must verify its discovery responses unless the responses contain only objections. For example, parties must include verifications when responding substantively to: Interrogatories, including both form and special interrogatories (Cal.
(b) Except as provided in Section 2030.070, no party shall, as a matter of right, propound to any other party more than 35 specially prepared interrogatories. If the initial set of interrogatories does not exhaust this limit, the balance may be propounded in subsequent sets.
Failing To Respond To Discovery Can Lead To A Dismissal Of Your Case With Prejudice. In the practice of law, the discovery phase can be your best friend or your worst nightmare. Interrogatories, requests for documents, and depositions can make or break your case.
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.
The party to whom interrogatories have been propounded shall respond in writing under oath separately to each interrogatory by (1) an answer containing the information sought to be discovered, (2) an exercise of the party's option to produce writings, or (3) an objection to the particular interrogatory.
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.
You have 30 days after the form or special interrogatories were served to you (35 days if served by mail from within California) to serve your responses to the interrogatories.
The motion to compel further responses has to be brought within 45 days of service of the response. (C.C.P.
