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    Past Due Discovery Response

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    As a paralegal, write a 1 page document to opposing counsel's paralegal regarding a past due discovery response. In this correspondence, tell the opposing paralegal that the discovery response is past due; that your office must have it by a certain date; if it is not forthcoming your office will file a Motion to Compel Discovery with the Court and ask for sanctions.

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    [Your Name, & Address here]

    To: (The opposing counsel)

    [Recipient Name & address here]

    [Date here]

    Dear [name],

    Sub - [write Case name]
    Case No. [Case no.]

    (Opposing Counsel) You were served [title of ...

    Solution Summary

    This solution presents a template for a past due discovery response.