Cuyahoga Ohio Discovery: Sample Letter to Opposing Counsel regarding Deposition and Subpoena Ducks Cecum [Your Name] [Your Address] [City, State, ZIP Code] [Email Address] [Phone Number] [Date] [Opposing Counsel's Name] [Opposing Counsel's Law Firm] [Address] [City, State, ZIP Code] Re: Discovery Request — Deposition and Subpoena Duces Tecum Dear [Opposing Counsel's Name], I hope this letter finds you well. I am writing to formally request your cooperation in the discovery process for the case [Case Name], pending in the Cuyahoga County Court of Common Pleas in Ohio. As part of our ongoing efforts to gather essential evidence, I would like to schedule a deposition and issue a subpoena duces tecum to obtain certain documents and materials from your client, [Defendant's Name]. Deposition: To effectively prepare our case, it is crucial to obtain sworn testimony from key witnesses, including your client. I request that you provide me with a list of available dates and times when [Defendant's Name] would be available for deposition. My intention is to engage in a fair and efficient process that accommodates both parties' schedules. Additionally, please let me know if there are any specific guidelines or restrictions we need to adhere to during the deposition. Subpoena Ducks Cecum: To supplement our existing evidence, it is imperative to acquire specific documents and materials in the possession, custody, or control of your client or any other relevant parties. I am enclosing a draft subpoena duces tecum in which I outline the specific items I seek. Please review the enclosed document carefully and, if you have any objections or suggestions, kindly inform me within [number of days] of receiving this letter. [Optional: If applicable] As per the discovery rules and procedures established by the Cuyahoga County Court of Common Pleas, I am also including a notice of intent to record the deposition. If you have any objections to recording the deposition, please notify me promptly. I propose that we collaborate in scheduling the deposition and discuss any necessary modifications to the subpoena duces tecum within [number of days] of your receipt of this letter. Your prompt attention to this matter will be greatly appreciated. If you have any questions or concerns, please do not hesitate to contact me directly at [Your Phone Number] or via email at [Your Email Address]. Thank you for your anticipated cooperation. I look forward to working together to ensure a smooth and seamless discovery process. Yours sincerely, [Your Name] [Your Law Firm] [Enclosures: Draft Subpoena Ducks Cecum, Notice of Intent to Record Deposition (if applicable)]