Sample Letter for Plaintiff's Motion to Compel the Production of the Documents Requested in Plaintiff's Second Request for Production of Documents in Harris Texas [Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] [Recipient Name] [Recipient's Law Firm] [Recipient's Address] [City, State, ZIP] Re: Case No. ________ — Motion to Compel the Production of Documents Dear [Recipient's Name], I hope this letter finds you well. I am writing regarding the above-mentioned case and to address the outstanding issue of the production of documents requested in Plaintiff's Second Request for Production of Documents. As you are aware, on [date], we served Plaintiff's Second Request for Production of Documents to which you have failed to provide a satisfactory response within the required time frame. Pursuant to the Texas Rules of Civil Procedure, specifically Rule ___, we kindly request that you promptly produce the requested documents or provide a valid reason for the failure to do so. The requested documents are essential to the prosecution of our client's case and are directly relevant to the issues at hand. We believe that the documents will provide important evidence that will support our claim and enable a fair determination of the matter. Consequently, we urge you to comply with this motion within [number of days, usually 14] of receiving this letter. In the absence of a sufficient response, we will be left with no choice but to seek relief from the court by filing a motion to compel the production of documents. This additional procedural step not only necessitates the expenditure of time and resources but may also result in adverse consequences of your client. It is in everyone's best interest to resolve this matter amicably and promptly. To assist in resolving this issue expeditiously, we are open to a meet-and-confer session to discuss any concerns you may have regarding the requested documents. We believe that a constructive dialogue may enable us to reach a mutually beneficial agreement and avoid the need for judicial intervention. Please be advised that if we do not receive a satisfactory response or initiate this meet-and-confer session within [number of days, usually 7], we will proceed with filing the Motion to Compel the Production of Documents. Thank you for your attention to this matter. We look forward to your prompt response and to resolving this issue without further delay or court intervention. Sincerely, [Your Name] [Your Title/Position] [Your Law Firm's Name, if applicable]