[Your Name] [Your Address] [City, State, Zip Code] [Email Address] [Phone Number] [Date] [Opposing Party's Name] [Opposing Party's Address] [City, State, Zip Code] Subject: First Interrogatories and Request for Production of Documents Dear [Opposing Party's Name], I hope this letter finds you well. I am writing to serve you with the First Interrogatories and Request for Production of Documents in relation to the ongoing matter [Case Number/Title] pending in [Court Name]. As per the Rules of Civil Procedure in New Mexico, I kindly request your timely response to the following interrogatories and document requests, within [number of days] of receiving this letter. Interrogatories: 1. Please state your full legal name, current address, telephone number, and occupation. 2. Please identify any individuals with knowledge of the facts surrounding [Case Number/Title] and provide their full names, addresses, and telephone numbers. 3. Identify all witnesses you intend to call at trial, providing their full names, addresses, and telephone numbers. 4. Please describe in detail your version of the events leading up to and surrounding [Case Number/Title]. 5. Please identify and provide copies of any written agreements or contracts relevant to [Case Number/Title], including any amendments or modifications. 6. Identify any expert witnesses you intend to call at trial, providing their full names, addresses, areas of expertise, and a summary of their expected testimony. 7. Identify any insurance coverage you hold that may be applicable to [Case Number/Title], including the name of the insurance company and policy number. Request for Production of Documents: 1. Please produce all documents, including contracts, letters, emails, and faxes, relating to [Case Number/Title], from [specific dates or timeframe]. 2. Provide copies of all medical records, invoices, and bills related to any injuries or medical treatment associated with [Case Number/Title]. 3. Produce all photographs, videos, or other visual recordings that depict the scene of the incident and/or your alleged injuries. 4. Provide copies of all relevant financial records, such as tax returns, bank statements, and pay stubs, over the past [specific years or timeframe]. 5. Please provide any insurance policies, including automobile, homeowners, or business policies, that may be applicable to [Case Number/Title]. 6. Produce any written statements, reports, or correspondence from expert witnesses retained or consulted in relation to [Case Number/Title]. Please note that these interrogatories and document requests pertain solely to the matters at hand and are expected to be treated pursuant to the applicable rules and procedures of New Mexico. Failure to timely and fully respond to these interrogatories and document requests may result in appropriate motions being filed with the court to compel discovery. Your timely and comprehensive responses are highly appreciated, as they will facilitate the process of resolving this matter efficiently and fairly. Should you require any clarification or have any concerns regarding these interrogatories and document requests, please do not hesitate to contact my office. Thank you for your attention to this matter, and I look forward to receiving your response by [deadline]. Sincerely, [Your Name] [Your Law Firm, if applicable] [Your Bar Number, if applicable]
New Mexico Sample Letter for First Interrogatories and First Set of Request for Production of Documents
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How to fill out Sample Letter For First Interrogatories And First Set Of Request For Production Of Documents?
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FAQ
Special Interrogatories can be used to identify relevant facts, witnesses, documents, historical information, etc., to each piece of evidence that the defendant has in their possession or should have in their possession. Requests for Admission should be used for foundational facts and legal issues.
Interrogatories allow the parties to ask who, what, when, where and why questions, making them a good method for obtaining new information in a case. There are two types of interrogatories: form interrogatories and special interrogatories.
You can use interrogatories to find out facts about a case but they cannot be used for questions that draw a legal conclusion.
How to Request Production of Documents and Things Download the template for Request for Production. ... Fill out basic information at the top. ... Choose a location for the other side to bring the documents. ... Add your own definitions (if useful) ... Write your requests for production. ... Sign and date the document. ... Make copies.
How to Write Draft Interrogatories Brainstorm questions to ask the non-party related to the issues in the case. Identify relevant documents, witnesses, or other evidence that will be needed to answer the interrogatories. Draft the interrogatories in written form. Ensure the interrogatories are clear, concise and specific.
You use discovery to get information or evidence from the other side in a lawsuit that will help you make your case. In order to get the information you need, you must make a request using a specific procedure and written format, within a specific timeframe.
Interrogatories, which are written questions about things that are relevant or important to the case. (NRCP 33; JCRCP 33) Requests for production of documents or things, which are written requests that demand the other side provide particular documents or items. (NRCP 34; JCRCP 34.)
A request for production is a discovery device used to gain access to documents, electronic data, and physical items held by an opposing party in a legal matter. The aim is to gain insight into any relevant evidence that the opposing party holds.
