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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.