Enforcement for Interrogatories - Letters

Initial Request Letter

Danny Delinquent, Esq.

222 Palm

Beverly Hills, CA 90210

RE: Peter Plaintiff v. Don Defendant

Dear Mr. Delinquent:

Please be advised that this firm represents __________________ in the titled action. In that regard, our office submitted a set of interrogatories to you, on ________, 20 __ to be answered by your client within the time permitted by the applicable court rules. That time has now expired. We would appreciate your client’s immediate attention to this matter.

Sincerely,

________________

Second Request Letter

Danny Delinquent, Esq.

222 Palm

Beverly Hills, CA 90210

RE: Peter Plaintiff v. Don Defendant

Dear Mr. Delinquent:

As you know, this firm represents __________________ in the above titled action. In that regard, our office submitted a set of interrogatories to you on _________, 20 __ to be answered by your client. As of this date, no answers have been received. On ________, 20 __ , we sent a letter reminding you about the unanswered interrogatories, but we have received no response. And, as you know, the time for filing objections has long expired.

Because the answers are crucial to our preparation of the case, and due to the fact that the court rules are quite strict with respect to discovery time limits, unless we are provided with full and complete answers to the interrogatories, we will be required to file a motion to compel answers. This, in turn, will entail a needless waste of time and expenditure of costs and attorney fees. I invite you to contact me and confer as soon as possible.

Sincerely,

_________________

Final Request Letter

Danny Delinquent, Esq.

222 Palm

Beverly Hills, CA 90210

RE: Peter Plaintiff v. Don Defendant

Dear Mr. Delinquent:

As you know, this firm represents __________________ in the above titled action. You are likewise aware that our office submitted a set of interrogatories to you on ______, 20 __ to be answered by your client. The time for answering or objecting to the interrogatories has long past. Despite repeated requests, written and otherwise, we have yet to receive any answers to our interrogatories. As indicated in my prior correspondence, we are left with no alternative but to file a motion to compel answers.

The applicable court rules require that we meet and confer in a good faith attempt to resolve our discovery problems. As you know, I have attempted to communicate with you on several occasions by mail [and by fax, telephone, email] but have not received any meaningful response. I must now seek your concurrence in the entry of an order that compels your client to answer each interrogatory completely and in detail and that such order provide for an award of the reasonable costs and attorney fees incurred by reason of your client’s delinquence.

Sincerely,

_________________

Letter Requesting Supplemental Answers ¹

Danny Delinquent, Esq.

222 Palm

Beverly Hills, CA 90210

RE: Peter Plaintiff v. Don Defendant

Dear Mr. Delinquent:

As...