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.© BrainMass Inc. brainmass.com March 22, 2019, 2:24 am ad1c9bdddf
[Your Name, & Address here]
To: (The opposing counsel)
[Recipient Name & address here]
Sub - [write Case name]
Case No. [Case no.]
(Opposing Counsel) You were served [title of ...
This solution presents a template for a past due discovery response.