[Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] [Judge's Name] [Court Name] [Court Address] [City, State, ZIP] Re: [Case Name and Number] Dear [Judge's Name], I am writing in response to the motion filed by [Opposing Party's Name] to reopen the deposition in the aforementioned case. I respectfully request that this motion be denied based on the following grounds. 1. Lack of Substantial Justification: The moving has failed to provide any substantial justification for reopening the deposition. They have not presented any new evidence, change in circumstances, or any valid reason explaining why it would be necessary to reopen the deposition. The motion appears to be solely aimed at gaining a tactical advantage rather than seeking the truth or ensuring fairness in this case. 2. Undue Delay and Prejudice: Granting the motion to reopen the deposition at this stage would result in undue delay and severe prejudice to our client. The discovery phase has been long concluded, and reopening the deposition would disrupt the orderly progress of this case. Moreover, our client would face considerable prejudice regarding the additional costs, efforts, and potential inconvenience associated with reconvening the deposition. 3. Prior Opportunity to Conduct Deposition Fully: It is important to note that the opposing party had ample opportunity during the original deposition to ask relevant questions, clarify concerns, and present their case fully. They failed to take advantage of these opportunities and cannot be permitted to reopen the deposition now. 4. No Exceptional Circumstances Rendered: The moving has not shown any exceptional circumstances that would necessitate reopening the deposition. They must establish compelling reasons or exceptional circumstances that warrant relief from the finality of the original deposition. Their motion fails to meet this threshold requirement. Based on these grounds, we kindly request that the court swiftly deny the motion to reopen the deposition. Granting such a motion would unjustifiably burden our client, cause unwarranted delay, and undermine the integrity of the discovery process. Thank you for considering our response, and we trust in the court's wisdom in ruling on this matter. Should you require any further information or clarification, please do not hesitate to contact me. Yours sincerely, [Your Name] [Your Position] [Your Law Firm's Name] [Your Law Firm's Address] [City, State, ZIP] [Email Address] [Phone Number] Keywords: Wisconsin, sample letter, order denying motion, reopen deposition, detailed description.
Wisconsin Sample Letter for Order Denying Motion to Reopen Deposition
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How to fill out Wisconsin Sample Letter For Order Denying Motion To Reopen Deposition?
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