[Your Name] [Your Address] [City, State, ZIP] [Date] [Opposing Party Name] [Opposing Party's Address] [City, State, ZIP] Re: First Set of Interrogatories — Production of Documents Dear [Opposing Party's Name], I hope this letter finds you well. As you are aware, we are currently engaged in [case name], and pursuant to the rules of discovery, it is now time for the exchange of interrogatories and production of relevant documents. I am writing to present you with the first set of interrogatories and request for production of documents. Please find the following interrogatories and documents we seek from you: Interrogatory Set 1: 1. Please provide a detailed description of your employment history, including the names and addresses of all employers, job titles, dates of employment, and reasons for leaving. 2. Identify all individuals who were present during [specific event/incident], providing their names, current addresses, and telephone numbers. 3. State whether you possess any knowledge of any documents related to [specific subject of the case], and if so, identify those documents and produce copies for our review. 4. Please provide a complete list of all expert witnesses you intend to call at trial, along with their qualifications, reports, and opinions they will testify to. 5. State whether you have photographs, videos, or any other visual or audio recordings that relate to the subject of this case. If so, please produce copies of those recordings. Document Production Requests: 1. Any and all contracts, agreements, or written communications between you and [relevant parties involved] pertaining to [specific subject of the case]. 2. Copies of all medical records, including but not limited to doctor's reports, test results, hospital bills, and prescriptions, that pertain to any injuries or medical treatment you received related to this case. 3. Provide copies of all correspondence, emails, letters, or text messages exchanged between you and any witnesses involved in this case. 4. All financial records, including tax returns, bank statements, and credit card statements, for the past [number of years], to establish the current financial status and credibility. 5. Any and all photographs, videos, or other visual evidence that you intend to rely upon during the trial. Please note that under the rules of discovery, you are required to respond to these interrogatories and produce the requested documents within [specify time, usually 30 days]. Failure to comply with these requests may result in the imposition of appropriate sanctions by the court. To facilitate a smooth and efficient discovery process, we propose that we meet and confer to discuss any concerns or objections you may have towards these interrogatories and document requests. Please let us know your availability for such a meeting. Thank you for your attention to this matter. We look forward to receiving your responses and the requested documents by the designated deadline. Sincerely, [Your Name] [Your Attorney's Name] [Law Firm Name] [Phone Number] [Email Address]
Connecticut Sample Letter for First Set of Interrogatories - Production of Documents
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Scope of Discovery: ?In any civil action, in any probate appeal, or in any administrative appeal where the judicial authority finds it reasonably probable that evidence outside the record will be required, a party may obtain in ance with the provisions of this chapter discovery of information or disclosure, ...
Interrogatories are often preferable to depositions for identi- fying such things as witnesses, documents, the dates and sub- stance of transactions and conversations,3 since a deponent may easily forget or overlook relevant information when an- swering such questions.
Your response to a request for production consists of two parts: One part is a written response to the requests, in which you state under penalty of perjury that you will produce the requested items; that you will not produce and why; or that you object to a request on legal grounds.
Answer only the question that is asked, and avoid the temptation to over-explain your answer. If the question contains several parts, you may break your answer into parts as well. It is also possible that you might object to the question.
Here are some of the things lawyers often ask for in discovery: anything a witness or party saw, heard, or did in connection with the dispute. anything anyone said at a particular time and place (for example, in a business meeting related to the dispute or after a car accident that turned into a lawsuit)
Unless otherwise stipulated or ordered by the court, a party may serve on any other party no more than 40 written interrogatories, including all discrete subparts. Leave to serve additional interrogatories may be granted to the extent consistent with Rule 26(b)(1) and (2).
Interrogatories are a discovery tool that the parties can use to have specific questions about a case answered before trial. Interrogatories are lists of questions sent to the other party that s/he must respond to in writing.
Answers to interrogatories can be much more complete than answers to deposition questions. Interrogatories are generally less expensive than depositions because they don't require court reporter fees, transcript costs, or attorney time in traveling to and from the deposition.
