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Write out each fact you wish the other party to admit is true. When writing these facts, be as clear and concise as possible. Each request must be for a single fact; do not include multiple facts, compound questions, or subparts.
SALUTATION or attention line: Address the reader by name punctuated with a colon. When writing to a manager you do not know by name or to a department, use an attention line. (Example: "Attention Claims Manager.") Avoid stuffy "Dear Sir" or "Dear Madam" salutations.
This letter is often called a good faith letter. And it is needed under many courts' rules before you can file a motion to compel discovery if the other party ignores your requests or provides evasive responses or move for sanctions if your opponent refuses to comply with the court's discovery order.
It's common to write "Attention' or 'ATTN colon' before the recipient's name. Use professional distinctions. If necessary, use titles such as Dr., CEO, or VP.
Discovery may be carried out by directly asking a person questions (oral depositions), by sending a person written questions (interrogatories and depositions on written questions), and by requesting that the person provide documents (motions for production, subpoenas duces tecum).