[Your Name] [Your Address] [City, State, ZIP] [Email Address] [Date] [Opposing Party's Attorney] [Attorney's Firm] [Address] [City, State, ZIP] Subject: Review of Answers and Objections to Plaintiff's 2nd Set of Interrogatories Dear [Opposing Party's Attorney], I hope this letter finds you well. I am writing on behalf of my client, [Your Name/Your Client's Name], in response to your submission of the Answers and Objections to Plaintiff's 2nd Set of Interrogatories in the above-mentioned case. Firstly, I would like to express our appreciation for providing the requested responses within the specified timeline. However, upon a thorough review of the answers and objections provided, we have identified certain concerns and discrepancies that require clarification and resolution. This letter serves as a formal request for review and further response as necessary. 1. General Objections: a. Lacks Specificity: Your objections frequently lack specificity, making it difficult for us to understand the basis for the objection. We kindly request you to provide more detailed explanations to clarify the grounds for your general objections. b. Unduly Burdensome: We believe your claim of undue burden in responding to certain interrogatories is unfounded. It is essential to reconsider whether your objections on this ground are valid in relation to the specific questions asked. c. Vague and Ambiguous: Many of your objections appear vague and ambiguous, hindering us in understanding your intended meaning. We kindly ask you to revise and provide clearer objections to facilitate efficient communication and resolution. 2. Specific Objections: a. Objection to Relevance: While we acknowledge that relevance objections are permissible, we disagree with several objections on this basis. We request that you review the questions carefully and provide a more targeted response, explaining the specific reasons for your objections. b. Privilege Objections: We have noted that certain privilege objections have been raised in response to interrogatories. We urge you to identify the specific privilege(s) invoked and provide a privilege log, as required by the applicable rules of civil procedure. c. Over breadth Objections: Several over breadth objections have been raised without sufficient explanation. We kindly request you to reconsider these objections and provide focused responses to the interrogatories, ensuring compliance with the relevant regulations. We anticipate your prompt attention to our concerns and request for clarification. Please be advised that in the absence of a timely response or resolution, we may seek appropriate remedies available under the law to address these deficiencies. To facilitate further discussion and resolution, we suggest a meet-and-confer session or a teleconference between the parties involved. This will help us address any outstanding issues, reduce unnecessary litigation, and promote a more efficient resolution of the matter. Thank you for your cooperation in this matter. We look forward to receiving your revised responses and further engaging in a productive dialogue. Yours sincerely, [Your Name] [Your Title] [Your Law Firm Name]
Puerto Rico Sample Letter for Review of Answer's and Objections to Plaintiff's 2nd Set of Interrogatories
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How to fill out Sample Letter For Review Of Answer's And Objections To Plaintiff's 2nd Set Of Interrogatories?
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FAQ
You can use interrogatories to find out facts about a case but they cannot be used for questions that draw a legal conclusion.
As the party resisting discovery by objecting to an interrogatory, you have the burden to explain why your objections are proper. To satisfy this burden, you should state your objection with specificity. This means giving specific facts, statutes, or judicial precedent supporting your position.
Your answers to the interrogatories should usually be short, clear, and direct and should answer only the question that is being asked. This is not the time to set out your entire case or defense to the other side. Take the time to make sure your answers are correct and truthful.
If you do not answer the questions by the deadline, which is usually about a month, the other side could ask the judge to order you to respond to the interrogatories. If you miss the second deadline, the judge could impose a fine against you or strike your pleadings.
Interrogatories are written questions sent by one party in a lawsuit to another party in that same suit, which the responding party must answer under penalty of perjury. Interrogatories allow the parties to ask who, what, when, where and why questions, making them a good method for obtaining new information.
Generally, interrogatories are objectionable if they seek information that is not within the scope of discovery as defined in Maryland Rule 402 or Federal Rule 26(b). These are typically requests that are not relevant, unduly burdensome, broad, vague, privileged. or protected by the work product doctrine.
If you are unable to answer an interrogatory because it is too vague, ambiguous, or somehow objectionable, you can state an objection and the reason for your objection. You must then answer to the extent the interrogatory is not objectionable.
Make a List of Questions Brainstorm questions to include in your interrogatories. Identify questions that are relevant to the issues in the case. Consider if the questions are legally permissible. Make sure the questions are direct, specific, and clear. Decide if the questions will help you gain any necessary information.
