Phoenix Arizona Sample Letter for Plaintiff's Motion to Compel Answers to Plaintiff's Second Set of Interrogatories

• Category: Letters - Legal - Documents
• State: Multi-State
• City: Phoenix
• Control #: US-0873LTR
• Format: Word; Rich Text

Description

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 Party's Name] [Opposing Party's Address] [City, State, ZIP] Re: Plaintiffs v. [Opposing Party] Case No: [Case Number] Dear [Opposing Party's Name], RE: MOTION TO COMPEL ANSWERS TO PLAINTIFF'S SECOND SET OF INTERROGATORIES I hope this letter finds you well. I am writing to bring your attention to the unsatisfactory responses provided by your client, [Opposing Party], in response to the Plaintiff's Second Set of Interrogatories served on [date of service]. As you are aware, [Opposing Party] has a legal obligation to respond fully, completely, and in a timely manner to all valid discovery requests, including interrogatories. However, the responses provided thus far are lacking in specificity, are incomplete, and fail to address crucial aspects of the Plaintiff's case. Therefore, we kindly request that you advise your client to provide more satisfactory responses within [reasonable timeframe — e.g., 14 days] from the date of this letter. Details regarding the deficiencies in the responses are outlined below: 1. Lack of Specificity: — Numerous interrogatory responses provided by [Opposing Party] contain vague, evasive, or general answers that fail to address the specific issues raised by the Plaintiff's interrogatories. Specific examples include [provide examples and briefly describe the issue]. 2. Incompleteness: — [Opposing Party]'s responses were incomplete, as several interrogatories were either partially answered or ignored entirely. Specifically, the following interrogatories were not sufficiently addressed [list specific interrogatories]. 3. Failure to Produce Requested Documents: — In conjunction with the interrogatories, the Plaintiff also requested the production of certain documents, as allowed by the applicable rules of discovery. To date, [Opposing Party] has failed to produce the requested documents. This non-compliance with the rules of discovery hampers the progression of this case. Due to the aforementioned deficiencies, we hereby move the Court to compel [Opposing Party] to provide complete, thorough, and specific answers to the Plaintiff's Second Set of Interrogatories within the stipulated timeframe. We kindly request that you inform your client of their obligation to cooperate fully and comply with the rules of discovery. Should [Opposing Party] fail to respond adequately within the provided timeframe, we will be left with no choice but to seek appropriate relief from the Court, including but not limited to sanctions for discovery abuses, costs, and attorney fees incurred as a result of this motion. Please apprise your client of the potential consequences associated with non-compliance and the importance of promptly addressing this matter. We hope to resolve this matter amicably without the need for court intervention. Thank you for your prompt attention to this matter. I look forward to receiving your client's revised and complete responses to the Plaintiff's Second Set of Interrogatories within the stipulated timeframe. Yours sincerely, [Your Name] [Your Title/Position] [Your Law Firm's Name]

[Your Name] [Your Address] [City, State, ZIP] [Date] [Opposing Party's Name] [Opposing Party's Address] [City, State, ZIP] Re: Plaintiffs v. [Opposing Party] Case No: [Case Number] Dear [Opposing Party's Name], RE: MOTION TO COMPEL ANSWERS TO PLAINTIFF'S SECOND SET OF INTERROGATORIES I hope this letter finds you well. I am writing to bring your attention to the unsatisfactory responses provided by your client, [Opposing Party], in response to the Plaintiff's Second Set of Interrogatories served on [date of service]. As you are aware, [Opposing Party] has a legal obligation to respond fully, completely, and in a timely manner to all valid discovery requests, including interrogatories. However, the responses provided thus far are lacking in specificity, are incomplete, and fail to address crucial aspects of the Plaintiff's case. Therefore, we kindly request that you advise your client to provide more satisfactory responses within [reasonable timeframe — e.g., 14 days] from the date of this letter. Details regarding the deficiencies in the responses are outlined below: 1. Lack of Specificity: — Numerous interrogatory responses provided by [Opposing Party] contain vague, evasive, or general answers that fail to address the specific issues raised by the Plaintiff's interrogatories. Specific examples include [provide examples and briefly describe the issue]. 2. Incompleteness: — [Opposing Party]'s responses were incomplete, as several interrogatories were either partially answered or ignored entirely. Specifically, the following interrogatories were not sufficiently addressed [list specific interrogatories]. 3. Failure to Produce Requested Documents: — In conjunction with the interrogatories, the Plaintiff also requested the production of certain documents, as allowed by the applicable rules of discovery. To date, [Opposing Party] has failed to produce the requested documents. This non-compliance with the rules of discovery hampers the progression of this case. Due to the aforementioned deficiencies, we hereby move the Court to compel [Opposing Party] to provide complete, thorough, and specific answers to the Plaintiff's Second Set of Interrogatories within the stipulated timeframe. We kindly request that you inform your client of their obligation to cooperate fully and comply with the rules of discovery. Should [Opposing Party] fail to respond adequately within the provided timeframe, we will be left with no choice but to seek appropriate relief from the Court, including but not limited to sanctions for discovery abuses, costs, and attorney fees incurred as a result of this motion. Please apprise your client of the potential consequences associated with non-compliance and the importance of promptly addressing this matter. We hope to resolve this matter amicably without the need for court intervention. Thank you for your prompt attention to this matter. I look forward to receiving your client's revised and complete responses to the Plaintiff's Second Set of Interrogatories within the stipulated timeframe. Yours sincerely, [Your Name] [Your Title/Position] [Your Law Firm's Name]