[Your Name] [Your Address] [City, State, Zip Code] [Date] [Opposing Party's Name] [Opposing Party's Address] [City, State, Zip Code] Re: First Set of Interrogatories — Production of Documents Dear [Opposing Party's Name], I hope this letter finds you well. I am writing to serve you with the First Set of Interrogatories and request for production of documents pursuant to the South Dakota Rules of Civil Procedure. This set of interrogatories and document production requests is aimed at obtaining essential information and documentation relevant to the ongoing legal proceedings in the matter of [Case Name], case number [Case Number], pending before the [South Dakota Court]. Please provide the following information and documents within [number of days, typically 30 days] from the date of this letter: 1. Interrogatories: a. Please state your full name, current address, and contact information. b. Provide a detailed account of your involvement in the events leading to the [incident/case] at issue. c. Identify all individuals who have knowledge of the events in question and provide their contact information. d. List all documents, photographs, or other tangible items you intend to rely upon at trial. e. Please describe any insurance policies that may be applicable to this case. f. Provide details of any prior legal proceedings or claims involving parties to this lawsuit. g. Describe any expert witnesses that you intend to call in connection with this case, including their areas of expertise and qualifications. 2. Request for Production of Documents: a. All documents related to [specific category — e.g., incident reports, police reports, medical records, correspondence, etc.]. b. All communications, including emails, text messages, and letters, related to the [incident/subject] of this lawsuit. c. Any relevant contracts, agreements, or other legal documents. d. Any photographs, videos, or recordings related to the [incident/subject] of this lawsuit. e. Copies of any documents or evidence you intend to introduce at trial. f. Any insurance policies in effect at the time of the [incident/accident] in question. g. Any financial records or transactions related to the [incident/subject] of this lawsuit. Please produce the requested documents in their original form or as otherwise available. If any of the requested items are not within your possession, custody, or control, please provide a detailed explanation and identify the party or individual who may possess them. Additionally, pursuant to South Dakota law, please inform me if any of the requested information or documents are privileged, confidential, or subject to any other protective order or privilege. If any such claims are made, please provide the basis and legal authority supporting your contention. Lastly, please be advised that your responses to these interrogatories and document production requests must be verified and provided under oath. If you require any clarification or extension of time to respond to this request, kindly contact me in writing within [number of days] of receiving this letter. Your timely and honest cooperation in providing the requested information and documents is essential for the fair and expeditious resolution of this matter. Thank you for your attention to this matter. Yours sincerely, [Your Name] [Your Title or Position, if applicable]