Maryland Discovery - Sample Letter to Opposing Counsel regarding Deposition and Subpoena Duces Tecum

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Multi-State
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US-0480LTR
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This form is a sample letter in Word format covering the subject matter of the title of the form.
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FAQ

Rule 2-403(a) allows a court, on motion, to restrict the scope of discovery otherwise permitted under Rule 2-402(a). Under Rule 2-403(a), the court may enter a protective order ?to protect a party from annoyance, embarrassment, oppression, or undue burden or expense.? P.

A subpoena may be served by a sheriff of any county or by any person who is not a party and who is not less than 18 years of age. A person may not serve or attempt to serve a subpoena more than 60 days after its issuance.

If the motion is denied, the court, after opportunity for hearing, shall require the (1) moving party, (2) the attorney advising the motion, or (3) both of them to pay to the party or deponent who opposed the motion the reasonable costs and expenses incurred in opposing the motion, including attorneys' fees, unless the ...

A motion for an order compelling discovery or for sanctions shall be filed with the court in which the action is pending, except that on matters relating to a deposition, the motion may be filed either with the court in which the action is pending or with the court in the county in which the deposition is being taken.

Rule 2-341 - Amendment of Pleadings (a) Without Leave of Court. A party may file an amendment to a pleading without leave of court by the date set forth in a scheduling order or, if there is no scheduling order, no later than 30 days before a scheduled trial date.

A party may obtain discovery regarding any matter that is not privileged, including the existence, description, nature, custody, condition, and location of any documents, electronically stored information, and tangible things and the identity and location of persons having knowledge of any discoverable matter, if the ...

Upon a motion filed under Rule 2-432(a), the court, if it finds a failure of discovery, may enter such orders in regard to the failure as are just, including one or more of the following: (1) An order that the matters sought to be discovered, or any other designated facts shall be taken to be established for the ...

(Md. Rule 2-431.) A non-party witness may file a written objection in response to subpoenas to produce material at a deposition or subpoenas to enter and inspect property.

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Maryland Discovery - Sample Letter to Opposing Counsel regarding Deposition and Subpoena Duces Tecum