This form is a sample letter in Word format covering the subject matter of the title of the form.
Dear [Name of opposing party], RE: Queens, New York — Sample Letter for First Interrogatories and First Set of Request for Production of Documents I hope this correspondence finds you well. As part of the ongoing legal proceedings in the case of [case name], I am writing to serve you with the First Interrogatories and First Set of Request for Production of Documents on behalf of my client, [Your Client's Name]. 1. FIRST INTERROGATORIES: Interrogatories are a crucial part of the discovery process that allow each party to obtain information from the other. Please find below a set of detailed interrogatories which my client seeks appropriate and prompt responses from your side: Interrogatory 1: Please identify and disclose all witnesses, including expert witnesses, you intend to present at trial and provide a brief summary of their anticipated testimony. Interrogatory 2: Identify all individuals with knowledge of relevant facts, including their names, addresses, and contact information, involved in [incident or subject of the case]. Interrogatory 3: Provide a detailed timeline of events leading up to and following the [incident or subject of the case], including dates, times, descriptions, and any documentation or evidence supporting your response. Interrogatory 4: State all facts, circumstances, and any applicable laws upon which you rely to support your defense in this case. Interrogatory 5: List all claims, counterclaims, or cross-claims you plan to assert against my client in this case, including any damages sought. 2. FIRST SET OF REQUEST FOR PRODUCTION OF DOCUMENTS: Request for Production of Documents is an essential component of discovery, wherein each party has the right to request relevant documents and evidence from the other party. Kindly provide the following documents within [reasonable time frame]: Request 1: All written agreements, contracts, or other documents pertaining to the [incident or subject of the case] involving any party in this lawsuit. Request 2: Any photographs, video recordings, surveillance footage, or other visual evidence related to the [incident or subject of the case]. Request 3: Copies of all relevant financial records, invoices, receipts, or other documents supporting any claimed damages in this case. Request 4: All communications, including emails, letters, text messages, and social media correspondences relevant to the [incident or subject of the case] between the parties involved or any other relevant individuals. Request 5: Any expert reports, opinions, or findings that you intend to rely upon or introduce at trial. Please note that this document request is not exhaustive, and my client reserves the right to seek additional documents as the case progresses. We kindly request that you provide your responses to the interrogatories and produce the requested documents within [reasonable time frame, typically 30 days from the date of this letter] to allow for a smooth and efficient discovery process. Should you require any extensions or modifications to the timeline or have any concerns about the requests presented, please notify me in writing. Failure to respond adequately or timely to these interrogatories may result in appropriate actions being taken, including motions to compel discovery, fee shifting, and other sanctions. Thank you for your cooperation in this matter. We look forward to receiving your responses and the production of relevant documents. Yours sincerely, [Your Name] [Your Law Firm] [Contact Information]
Dear [Name of opposing party], RE: Queens, New York — Sample Letter for First Interrogatories and First Set of Request for Production of Documents I hope this correspondence finds you well. As part of the ongoing legal proceedings in the case of [case name], I am writing to serve you with the First Interrogatories and First Set of Request for Production of Documents on behalf of my client, [Your Client's Name]. 1. FIRST INTERROGATORIES: Interrogatories are a crucial part of the discovery process that allow each party to obtain information from the other. Please find below a set of detailed interrogatories which my client seeks appropriate and prompt responses from your side: Interrogatory 1: Please identify and disclose all witnesses, including expert witnesses, you intend to present at trial and provide a brief summary of their anticipated testimony. Interrogatory 2: Identify all individuals with knowledge of relevant facts, including their names, addresses, and contact information, involved in [incident or subject of the case]. Interrogatory 3: Provide a detailed timeline of events leading up to and following the [incident or subject of the case], including dates, times, descriptions, and any documentation or evidence supporting your response. Interrogatory 4: State all facts, circumstances, and any applicable laws upon which you rely to support your defense in this case. Interrogatory 5: List all claims, counterclaims, or cross-claims you plan to assert against my client in this case, including any damages sought. 2. FIRST SET OF REQUEST FOR PRODUCTION OF DOCUMENTS: Request for Production of Documents is an essential component of discovery, wherein each party has the right to request relevant documents and evidence from the other party. Kindly provide the following documents within [reasonable time frame]: Request 1: All written agreements, contracts, or other documents pertaining to the [incident or subject of the case] involving any party in this lawsuit. Request 2: Any photographs, video recordings, surveillance footage, or other visual evidence related to the [incident or subject of the case]. Request 3: Copies of all relevant financial records, invoices, receipts, or other documents supporting any claimed damages in this case. Request 4: All communications, including emails, letters, text messages, and social media correspondences relevant to the [incident or subject of the case] between the parties involved or any other relevant individuals. Request 5: Any expert reports, opinions, or findings that you intend to rely upon or introduce at trial. Please note that this document request is not exhaustive, and my client reserves the right to seek additional documents as the case progresses. We kindly request that you provide your responses to the interrogatories and produce the requested documents within [reasonable time frame, typically 30 days from the date of this letter] to allow for a smooth and efficient discovery process. Should you require any extensions or modifications to the timeline or have any concerns about the requests presented, please notify me in writing. Failure to respond adequately or timely to these interrogatories may result in appropriate actions being taken, including motions to compel discovery, fee shifting, and other sanctions. Thank you for your cooperation in this matter. We look forward to receiving your responses and the production of relevant documents. Yours sincerely, [Your Name] [Your Law Firm] [Contact Information]