This form is a sample letter in Word format covering the subject matter of the title of the form.
[Your Name] [Your Address] [City, State, ZIP] [Date] [Opposing Counsel's Name] [Opposing Counsel's Address] [City, State, ZIP] Re: Plaintiff's Motion to Compel the Production of Documents Requested in Plaintiff's Second Request for Production of Documents Dear [Opposing Counsel's Name], I hope this letter finds you well. I am writing to discuss the outstanding production of documents requested in Plaintiff's Second Request for Production of Documents in the wake of our ongoing litigation in Wake, North Carolina. Pursuant to Rule X of the Wake County Superior Court Rules and the North Carolina Rules of Civil Procedure, I hereby move the Court to compel the production of these crucial documents that have yet to be provided by your client. [If applicable, mention the types/nature of the requested documents here: e.g., financial records, correspondence, contracts, emails, etc.] Despite our previous discussions and your acknowledgment of these requests, it has come to my attention that the documents have not been produced within the stipulated time period. This Motion to Compel is filed due to the necessity for these documents in forming a complete and accurate understanding of the facts surrounding this case. Plaintiff's Second Request for Production of Documents was initially served upon you on [date], and as of the date of this letter, we have received no response or objection regarding their availability. It is crucial for the efficient administration and fair resolution of this case that all relevant documents be promptly produced. Failure to do so not only impedes the discovery process but also undermines the fundamental principles of procedural fairness and justice. Considering the previously established deadline for the production of the requested documents has lapsed, we kindly request that you produce the requested documents within 14 days of receiving this letter. If you believe you cannot comply with the production of these documents by the specified deadline, please provide a detailed explanation in writing, setting forth the specific grounds of your objection or any other valid reasons for the delay. Should you fail to provide a satisfactory response or objection within the specified timeframe, we will not hesitate to seek appropriate legal remedies, including but not limited to filing a Motion to Compel and seeking sanctions for any resulting expenses incurred by our client due to the delay in producing these documents. In the spirit of professionalism and cooperation, I trust that you will promptly address this matter and ensure compliance with the rules of discovery. I hope we can work together to resolve this issue without any further intervention from the Court. Please be advised that if we do not receive a satisfactory response within the given timeframe, we will proceed with filing the necessary motion and seeking appropriate relief. Thank you for your attention to this matter. I look forward to your prompt response. Sincerely, [Your Name] [Your Law Firm] [Phone Number] [Email Address]
[Your Name] [Your Address] [City, State, ZIP] [Date] [Opposing Counsel's Name] [Opposing Counsel's Address] [City, State, ZIP] Re: Plaintiff's Motion to Compel the Production of Documents Requested in Plaintiff's Second Request for Production of Documents Dear [Opposing Counsel's Name], I hope this letter finds you well. I am writing to discuss the outstanding production of documents requested in Plaintiff's Second Request for Production of Documents in the wake of our ongoing litigation in Wake, North Carolina. Pursuant to Rule X of the Wake County Superior Court Rules and the North Carolina Rules of Civil Procedure, I hereby move the Court to compel the production of these crucial documents that have yet to be provided by your client. [If applicable, mention the types/nature of the requested documents here: e.g., financial records, correspondence, contracts, emails, etc.] Despite our previous discussions and your acknowledgment of these requests, it has come to my attention that the documents have not been produced within the stipulated time period. This Motion to Compel is filed due to the necessity for these documents in forming a complete and accurate understanding of the facts surrounding this case. Plaintiff's Second Request for Production of Documents was initially served upon you on [date], and as of the date of this letter, we have received no response or objection regarding their availability. It is crucial for the efficient administration and fair resolution of this case that all relevant documents be promptly produced. Failure to do so not only impedes the discovery process but also undermines the fundamental principles of procedural fairness and justice. Considering the previously established deadline for the production of the requested documents has lapsed, we kindly request that you produce the requested documents within 14 days of receiving this letter. If you believe you cannot comply with the production of these documents by the specified deadline, please provide a detailed explanation in writing, setting forth the specific grounds of your objection or any other valid reasons for the delay. Should you fail to provide a satisfactory response or objection within the specified timeframe, we will not hesitate to seek appropriate legal remedies, including but not limited to filing a Motion to Compel and seeking sanctions for any resulting expenses incurred by our client due to the delay in producing these documents. In the spirit of professionalism and cooperation, I trust that you will promptly address this matter and ensure compliance with the rules of discovery. I hope we can work together to resolve this issue without any further intervention from the Court. Please be advised that if we do not receive a satisfactory response within the given timeframe, we will proceed with filing the necessary motion and seeking appropriate relief. Thank you for your attention to this matter. I look forward to your prompt response. Sincerely, [Your Name] [Your Law Firm] [Phone Number] [Email Address]