Pennsylvania Sample Letter for Plaintiff's Motion to Compel the Production of the Documents Requested in Plaintiff's Second Request for Production of Documents

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Multi-State
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US-0872LTR
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This form is a sample letter in Word format covering the subject matter of the title of the form.

Subject: Pennsylvania Sample Letter for Plaintiff's Motion to Compel Production of Requested Documents Dear [Recipient's Name], I hope this letter finds you well. I am writing to discuss a matter pertaining to the pending case [Case Name] and the Plaintiff's Second Request for Production of Documents. As part of the discovery process, the Plaintiff submitted a Second Request for Production of Documents on [Date]. However, as of [Current Date], the Defendant has failed to produce the requested documents, leading to a significant delay in the proceedings. The purpose of this letter is to serve as the Plaintiff's Motion to Compel the Production of the Documents Requested in the Plaintiff's Second Request for Production of Documents. It is crucial that the Defendant promptly complies with the discovery rules and fulfills their obligation to produce the requested documents. The Plaintiff contends that the requested documents are relevant to the case and are essential for the fair determination of the issues at hand. The failure to produce these documents severely hampers the Plaintiff's ability to adequately prepare for trial, resulting in unnecessary prejudice and a violation of their rights. The documents being sought fall into various categories, including but not limited to: 1. Financial Records: Please provide all financial documents, including bank statements, tax returns, pay stubs, receipts, and any other records that pertain to [specific timeframe]. 2. Medical Records: In accordance with the Plaintiff's Second Request for Production of Documents, the Defendant is required to produce all medical records, including but not limited to doctor's reports, test results, hospital records, prescriptions, and any other documentation relevant to the Plaintiff's medical history. 3. Correspondence: Any letters, emails, memos, or other forms of written communication between the Defendant and the Plaintiff, as well as any communication involving relevant third parties, are to be produced. 4. Contracts and Agreements: Please provide copies of all contracts, agreements, or any binding documents that relate to the matters at issue in this case. It is crucial that the Defendant complies with the request for production without further delay or objection. The Plaintiff seeks to obtain the requested documents within [reasonable timeframe], as the case is currently pending and the discovery process is nearing its conclusion. Failure to provide the requested documents will force the Plaintiff to seek appropriate legal remedies, which may include sanctions under Pennsylvania Rules of Civil Procedure, Section [Section Number]. It is our sincere hope that such measures will not be necessary and that the Defendant will fulfill their obligations in a timely manner. We kindly request the Defendant's immediate attention to this matter and the prompt production of the requested documents within [specified timeframe]. Please contact me at [your contact information] to discuss any concerns or should you require any further clarification. Thank you for your attention to this important issue. Sincerely, [Your Name] [Your Law Firm] [Address] [City, State, ZIP] [Phone Number] [Email Address]

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Check or type: "I cannot comply with the request because no such documents or things exist. A diligent search and reasonable inquiry have been made in an attempt to comply with this demand.? Check or type: ?I cannot comply with the request because the documents or things are no longer in my possession and control.

Grounds For Motion ? A party may move to compel the production of documents or things if the response (1) agrees to comply, but compliance is incomplete, (2) the responding party's indication of inability to comply is incomplete, inadequate, or evasive, or (3) an objection to a request is made that is too general or ...

Requests for Production or Demands for Inspection require you to produce documents for copying or in some cases actual items for inspection. Responding to the request has 2 parts: State if you can comply with the request (all of it or some of it) or give the reason why you can't comply.

Pennsylvania Rule of Civil Procedure 4019(a)(1)(i) provides that ?[t]he court may, on motion, make an appropriate order if a party fails to serve answers, sufficient answers, or objections to written interrogatories.?

A Motion to Compel is a formal request to the Court to require a party or a non-party in a lawsuit to comply with a discovery request such as a request for production, request for admission, interrogatory, or subpoena.

SUPPLEMENTAL REQUEST FOR PRODUCTION If, for any reason, any response is no longer correct or complete, identify the response and state and/or provide copies of whatever information and/or documentation is necessary in a verified response to make it correct and complete as of this date.

Complete Your Written Responses That the request will be allowed in whole. ... That you are unable to comply with the request, because the requested document or thing has never existed. ... That you are unable to comply because the requested items no longer exist, or are no longer in your possession.

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.

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Apr 11, 2019 — Attached are courtesy copies of those documents, specifically,. Plaintiffs' First Request for Production of Documents to Defendants ABC Capital. Mar 18, 2011 — RESPONSIVE TO PLAINTIFFS' FIRST REQUEST FOR DOCUMENTS​​ For the reasons set forth below, this Court should grant Plaintiffs' motion to compel and ...Mar 22, 1999 — Plaintiff's Responses And Objections To Defendant's Second Request for Documents and First Set Of Interrogatories. Share right caret. Request for Production of Documents​​ If the plaintiff does not respond to the court order, then you can file a Motion to Dismiss and you may win your case. The following is the discovery issue we need to resolve: With respect to Request for Production No. 1, wherein I requested “Plaintiff's personnel file,” you ... (iv) a party fails to produce documents or fails to respond that inspection ... (a) and compelling inspection in accordance with a request made under Rule 34. Feb 16, 2017 — In pursuing the argument that the records. Requester sought were exempt from public access because the records related to a judicial order, ... When a motion to compel discovery is filed in accordance with Rule of Civil Procedure. 1.380(a)(2) and the motion alleges a. a complete failure to respond ... If this subpoena commands the production of documents, electronically stored information, or tangible things or the inspection of premises before trial, a ... If so, please consider this a Request to Produce such document or documents. 10. State the name and last known address of each person who (a) was a witness ...

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Pennsylvania Sample Letter for Plaintiff's Motion to Compel the Production of the Documents Requested in Plaintiff's Second Request for Production of Documents