Letter conference meet and confer agreements

To: [Responding party's counsel]

[Address]

Dear [Name]:

This letter confirms the agreements we reached during the [date] meet and confer session we held at [location] regarding [describe subject of meet and confer, e.g., defendant’s responses to plaintiff’s first request for production of documents, interrogatories, etc.].

[List each discovery request over which a dispute exists and the status of discussions. For example:]

First, you will advise me by [date] as to whether you have any...