Letter Re: Responses to Discovery



Letter Re: Responses to Discovery

| |LAW OFFICES OF | |

| |TERRY BAYLOR | |

|TERRY BAYLOR |2140 DESERT DRIVE, SUITE 123 |SANDRA D. STEVENS |

| |DESERT VILLAGE, CALIFORNIA | Legal|

| | |Assistant |

| |TEL: (555) 555-1234 FAX: (555) 555-5678 | |

January 12, 2004

ATTORNEY-CLIENT PRIVILEGED COMMUNICATION

Margaret Wayne

963 Jean Street

Desert Village, CA

Re: Wayne v. Ferrer Hardy

Dear Ms. Wayne,

Please find enclosed a copy of the form and special interrogatories, and document request (first sets) served on our office on your behalf by the defendant’s attorney.

The date by which we must supply responses and documents is February 9, 2004. Therefore, it is imperative that we receive from you your draft responses to each of the checked form interrogatories, and all of the special interrogatories by February 1, 2004. This will give us an opportunity to prepare the official responses and serve them by the date required.

Please understand that we will be preparing appropriate responses to each interrogatory, including objections where necessary. (For example, we will object and refuse to supply your social security number.) However, you will facilitate the discovery process, and save us time and money, by supplying all of the information required by the interrogatories.

We will also prepare the written response to the document request, and the responsive documents. When we undertook this matter we obtained from you a substantial amount of documentation, which we will use to prepare our responses. However, please review the requests carefully to determine whether you (or anyone over whom you have control such as a CPA or tax advisor) has any other responsive documents. Also, please understand that the “documents” to which these requests refer include electronic documents such as email communications and computer files, and photographs, tape recordings, etc. Please call me if you have any questions and I’d be happy to help you collect the necessary responsive documents.

Finally, I also enclose verifications for each of the discovery items. Please note that each requires your signature under oath. Once you have provided us with your draft responses, we will complete proposed responses for your review and approval. Once you

have reviewed them and approved them, we will ask you to provide us with your original signature on each of the verifications. Because all of your responses are under oath, it is critical that they be as accurate as possible.

As we discussed by telephone, it is likely that upon receipt of these responses, the opposition will notice your deposition. Please call me to let me know of your availability over the next several months so that we can set a date that does not conflict with any travel or other plans you may have. We will also provide adequate time to prepare you for the deposition itself so that you are familiar with the process and the issues that may be raised.

Please do call if you have any questions or if I may be of assistance in any way.

Sincerely,

Sandra Stevens

Legal Assistant

SS/

Encls.

................
................

In order to avoid copyright disputes, this page is only a partial summary.

Google Online Preview   Download