Subject: Bronx New York Discovery — Sample Letter to Opposing Counsel: Deposition and Subpoena Ducks Cecum Dear [Opposing Counsel's Name], I hope this letter finds you well. In accordance with the Bronx New York Discovery process, I am writing to discuss the forthcoming deposition and the issuance of a subpoena duces tecum in the case of [Case Name] in which we are both involved. 1. Deposition: As you may be aware, the deposition is a fundamental part of the discovery process where we gather sworn testimony from witnesses, including parties involved, in order to obtain relevant information and clarify pertinent facts surrounding the case. It allows both parties to examine and cross-examine witnesses under oath. The deposition provides an opportunity to explore the strengths and weaknesses of the respective party's case, aiding in the negotiation and resolution of the dispute. Given the importance of conducting an efficient and productive deposition, I kindly request that we mutually agree on a suitable date, time, and location for this deposition. It is crucial that we choose a neutral and easily accessible location to ensure convenience for all parties involved. Additionally, we should discuss agreed-upon guidelines and rules regarding the scope of questioning, time restrictions, and any potential objections to questions raised during the deposition. Please provide your availability over the next few weeks so that we can expedite this process. 2. Subpoena Ducks Cecum: In addition to the deposition, I intend to issue a subpoena duces tecum for the production of documents or tangible evidence relevant to the case. This legal instrument enables us to request specific documents, records, or other physical evidence that may strengthen our understanding of the matter at hand. It will help in assessing liability, damages, and formulating an effective legal strategy. To ensure a smooth and timely exchange of documents, I kindly request that you promptly provide a list of pertinent documents you plan to present as part of your case. Additionally, please advise if there are any specific protocols or preferences you have for sharing these materials, such as electronic delivery or physical submission. Your cooperation in timely and complete disclosure of requested documents will greatly contribute to the progress of our case and aid in a fair resolution. If you have any concerns or suggestions regarding the deposition or the issuance of the subpoena duces tecum, please do not hesitate to share them with me. I firmly believe that open communication and collaboration between both parties will expedite the discovery process and enhance the overall efficiency of this legal matter. Thank you for your attention to this matter. I look forward to receiving your response and collaborating on the scheduling of the deposition as well as the subpoena duces tecum. Yours sincerely, [Your Name] [Your Firm Name] [Your Contact Information]