You have to deal forcefully with opposing attorneys and gently with insurance commissioners who ask you to account for the way you handled a particular case. Never use slang, emojis, or cute semantics. This is both for potential clients and potential referring lawyers throughout the United States. Attorneys have a duty to their clients to ensure sensitive information never ends up in the wrong hands. Been over two weeks still no response. A good faith attempt is more than arguing with opposing counsel. Any payment received or tendered after the 30 days must include interest at the rate of 12 percent per annum. Pending child support modification case for several months. To dispense with dear, I believe, is to sound abrupt. SHRM Employment Law & Compliance Conference, Attorney-Client Privilege: What You Need to Know, New OSHA Guidance Clarifies Return-to-Work Expectations, Trump Suspends New H-1B Visas Through 2020, Faking COVID-19 Illness Can Have Serious Consequences, White House Takes Action Against Migrant Child Labor, Report: Managers Have Bigger Impact on Employee Mental Health than Therapists, How to Handle Overtime, Meal Break and Other Wage and Hour Crises. The courts findings are consistent with Rule 1.6(e), which requires attorneys to take reasonable steps to avoid an inadvertent disclosure of confidential information. This letter is not arrogant, merely a bit vague in its pinning the $1,700 offer to certain measurable specific expenses (e.g., X-rays and treatment). Why not just go with "Sincerely"? if(currentUrl.indexOf("/about-shrm/pages/shrm-china.aspx") > -1) { 12-2021) Page 1 of 1 TexasLawHelp [Date letter sent] [Your name, printed] [Your street address.] You will make mistakes. Example lawyer letter of representation to the insurance company or opposing counsel in a civil claim. Since you're a paralegal extraordinaire, you know that you'll only have 45 days to file and serve your motion to compel. Ct. 2007) (enjoining plaintiffs counsel from communicating directly with defendants board of directors); In Re Illuzzi, 616 A.2d 233 (Vt. 1992) (six month suspension for a lawyer with significant disciplinary history for, among other things, communicating directly with insurance adjusters regarding litigation matters being handled by outside counsel). In the event the receiving attorney knows that opposing counsel inadvertently included the opposing party on the email communication, the receiving attorney shall promptly notify the sender and shall not examine the materials. Rule 4.4(b). No need to explain unless you've received multiple extensions already. If you can show methat myclients cases are unlikely to survive summary judgment, then Iwill advise themto dismiss their claimsand try to move on with their lives. You objected to this request on the basis it seeks documents protected by the attorney-client communication privilege and the attorney work product doctrine. As you are doing the initial review of documents, create a document to catalog what was produced and what is missing. *6. You have not indicated whether any materials like this exist. Most law firms keep copies of every letter they send or receive for each individual case. The "RE" line, being a bit lengthy, could be placed to the right side of the page. The attorney-client privilege is a way to address communication to your outside or in-house counsel when you need to send a message (i.e., letter or email) but don't want it to be potentially discoverable by opposing counsel if a lawsuit were to ensue. However, copying a client on a communication sent to opposing counsel is fraught with risk. Now that defendant has named experts, please provide a response to this request. 01. The danger in copying your client on an email to opposing counsel is that your client may hit reply to all, either by mistake or on purpose. 6 on the basis that it exceeds the scope of expert discovery under Rule 2-402(f). Md. Again, based on the review of the medical information on your client, I wish to offer $1,700.00. Further, if you have any question whether or not you should be invoking the attorney-client privilege, always err on the side of caution and protect the documentation trail as much as possible. You may be challenged in sustaining the privilege if you simply copy your attorney on your various emails without asking for official legal advice. $(document).ready(function () { For your claims department, this is money in the bank. Dear : [Print name of the other party's lawyer (opposing counsel).] [Details Here], Please provide your legal analysis and opinion at your earliest convenience. If you enjoyed this article, let us know on social media! function of your email program can really save the day. You must at least tell me if any responsive materials exist, so that I may seek the assistance of the Court in resolving your objection. At the outset, Ill let you know that while standing up for people who were harmed by others is the driving force behind this firm, another reason why my practice is thriving is thatI make sound business decisions. Please note that all such forms and policies should be reviewed by your legal counsel for compliance with applicable law, and should be modified to suit your organizations culture, industry, and practices. Here are four statements, taken from actual letters to attorneys, that I feel go overboard in their emotionality. We submitted a set of Interrogatories and Requests for Production of Documents to your client on February 1, 2022. The rest of the response says that defendant cannot respond because it has not yet selected experts. And it is needed under many courts rules before you can, file a motion to compel discovery if the other party ignores your requests or provides evasive responses. Upon review, courts may consider several factors in determining whether a copy or blind copy is sufficient to constitute consent, including: (1) how the communication was initiated; (2) the nature of the matter (transaction or adversarial); (3) the prior course of conduct of the lawyers and their clients; and (4) the extent to which the communication might interfere with the attorney-client relationship. Follow these five tips and youll make it easier to avoid mistakes that could potentially harm the integrity of your firm. LASC: ELECTRONIC FILING OPTION FOR PROBATE LETTERS BEGINS MARCH 1, BECOMES MANDATORY ON MAY 30 FOR REPRESENTED PARTIES, ALAMEDA COUNTY SUPERIOR COURT: UPCOMING SYSTEM MAINTENANCE, RIVERSIDE COUNTY SUPERIOR COURT: UPCOMING SYSTEM MAINTENANCE, SAN BERNARDINO SUPERIOR COURT: GOING LIVE SOON WITH PROBATE EFILING, LASC: APPELLATE DIVISION SEEKS ATTORNEYS TO REPRESENT INDIGENT DEFENDANTS. I look forward to working with you. Anyone involved in any part of the litigation process knows that communication with opposing counsel must be carefully monitored. But before you reach out to me with an offer, I want there to be no misunderstanding or miscommunication regarding how my firm approaches, responds to, and conducts settlement discussions, or the terms which any settlement must include. Your Trusted Source for risk management and insurance information, education, and training, IRMI Headquarters You have done the same thing in Response Nos. Edit your letter opposing counsel settlement online Type text, add images, blackout confidential details, add comments, highlights and more. This is also true in federal court under Rule 37(f). This question is relevant and proper based on this litigations subject matter. . Take advantage of the top and . On Discovery and Email. In other words, you can't send an email to your non-attorney boss and mark it "privileged and confidential" because without an attorney on the receiving end to provide legal analysis and advice, there's no mechanism to protect the communication from legal discovery. This letter addresses these deficiencies. Tell the client that your withdrawal at this time shouldn't prejudice . The court further stated that continued carelessness may compel a finding of waiver. Id. There are three reasons to meet and confer with your opponent when its discovery answers are evasive or incomplete. The contact form sends information by non-encrypted email, which is not secure. Read the latest Past Presidents Reflect piece by Fred W. Alvarez, 2000 BASF President: http://bit.ly/3IbhFBl, Need CLE credit in Estate Planning, Probate & Trust Law? Your general objections make it challenging to determine what interrogatories and requests you think these objections apply to and the reason you find the questions improper. ", "Keeping in mind that our insured made a dent the size of a small grapefruit in your client's bumper, I must ask you, what could possibly have been your client's injuries? So, in addition to training your colleagues to master those important technical insurance skills, you might want to teach them the art of writing to lawyers without falling into the stodgy, arrogant, and overbearing writing habits that, sadly, most lawyers embrace and perpetuate. 2009-01 (Jan. 2, 2009). [Name of opposing party or counsel] [Address of opposing party or counsel] Re: [Case description or incident on which suit is based] [Salutation] Please be advised that my law firm and I have been retained by [name of client] to pursue a cause of action against you[OPTIONAL: in or based on] the above-referenced matter. When you need Sample Email To Opposing Counsel, don't accept anything less than the USlegal brand. The nature of the case. My firm represents Paul Plaintiff in his negligence claim against your client, Doug Defendant. If youre calendaring system has the capacity for notes and attachments, be sure to note original due date, dates when new agreements were reached, new production dates, etc. The court rules require us to meet and confer in a good faith attempt to resolve our discovery disagreements. *5. 13 on the basis that it is vague, overly broad and unduly burdensome, fails to describe the documents sought with reasonable particularity, and seeks documents that are proprietary and confidential. This request is directed at discovering documents or other materials relevant to the defendants policies and training regarding floor care, and slips, spills, and falls. The contact form sends information by non-encrypted email, which is not secure. If you are looking for help in handling your accident/malpractice/product liability/premises liability case, call 800-553-8082 or get a free online no obligation consultation. Instead, objections to reasonable Interrogatories must be specific to each Interrogatory and explain or demonstrate precisely why or how the party is entitled to withhold from answering. Please let others on your team know that and share my contact information with them. Attach a copy of the motion you filed with the court to be relieved as counsel. 17 on the basis that it seeks information protected by attorney work product, attorney-client privilege and/or materials prepared in anticipation of litigation. You need to tell me what material there is that is being withheld under any of these privileges, and which privilege you contend applies, so I may seek the assistance of the Court in resolving your claims of privilege. This skill doesn't get much play in college writing courses. Remain open to a confidentiality agreement and tax indemnification, as permitted by law. The first email you write to a partner in a law firm is nerve-wracking. As plaintiffs' lawyers, we have to hold the defendant's feet to the fire or you are going to have a jury trial by ambush. If you dont have 100% clarity on who should receive copies of your emails, ask early and often. By setting a rule that your emails wont go out for several minutes after you press send, you give yourself the chance to review its contents in case you missed an error. Which Im happy to do; as a contingent-fee plaintiffs lawyer, I embrace the risks inherent in trusting the adversarialprocess and Im accustomed tobetting on myselfand my clients rather than trying to negotiate with adversaries who wont cede an inch. "Present in the past" ought to read "preexisting", "You can rest assured that with all the old damage on the car, no dealer would offer you clean value for your car and they would still take the deduction for all the old damage. The rest of the response says that defendant cannot respond because it has not yet selected experts. You have objected to Request No. #1: Consider everything you put in writing to be an exhibit that will end up in front of the judge. If you have ever received a rude email from opposing counsel, it can be so tempting to fire back. This notice should be prominent and easily viewable as soon as someone receives the communication. Please log in as a SHRM member. DEFICIENCY OF YOUR ANSWER TO INTERROGATORY #11. ", "Do you think a jury will find it odd that there were no indications of facial injuries immediately after the accident, yet she now contends that she has problems with her teeth and ringing in the ears? Lastly, ask for confirmation in writing from opposing counsel . Rule 5: Do not communicate the information discussed with the attorney with others unless instructed to do so. You can also download it, export it or print it out. And one of their favorite tactics to delay payment of claims is to make baseless objections or provide incomplete or evasive answers to discovery requests (interrogatories, requests for production of documents, requests for admissions, etc.). If you received a data dump, draft a letter or an email for your attorney to send to opposing counsel reminding them of their duty under CCP 2031.280 (a). You will panic. Raise your level of accountability by using this tip to ensure that your emails with opposing counsel are based on professionalism and adheres to court rules. In addition, the sending lawyer may create a risk of implied consent for opposing counsel to communicate with his or her client under Rule 4.2. Sample Letter to Opposing Counsel Regarding Discovery. Pay any portionof mediation costs unless the other side first makes a reasonable settlement offer or the Court orders us to. A good rule of thumb for writing any email is to not write anything that youd feel embarrassed about later down the road. Below is a sample letter to opposing counsel asking your opponent to fix inadequate discovery responses and give more complete answers. That said, if you merely dispute myclients factual allegations without providing any corroborating evidence (e.g., sworn statements, emails,phone records, etc.) The PMQ teaches managers to lead effectively, giving HR more time to meet the demands of the workplace. We are uniquely qualified and have proven to bring continued success to our clients. Please provide your clients responses within ten days. Instead, I generally dont get paid unless I recover money for my clients, therefore it makes all the sense in the world for me to keep an open mind and absolutely no sense for me to prosecuteclaims destined to fail. for sending emails suggests that before you send an email, you should make sure its contents wouldnt embarrass you if it ended up on the front page of the Times. Before you send an email to opposing counsel, consider how the judge in your case would take it if your email ended up as an exhibit to a motion. Ask your attorney to communicate your rescision to opposing counsel. He felt that she had healed 100 percent. Call now for a free consultation: (804) 251-1620 or (757) 810-5614. Please understand I am not denigrating you. I understand that your firms antiquated business model evaluates you based on the numberof your billable hours. As a rule, try and limit the audience to either only the attorney or to the attorney plus one other person (for example, your boss). You must at least tell me if any responsive materials exist, so that I may seek the assistance of the Court in resolving your objection. } 10-C-10-018419 OT. Infact, when I left the biglaw firm in 2009 to hang a shingle, my litigation strategy wasto immediately open a frank and candid discussion with the other sides lawyerabout the strengths and weaknesses of the case under the naiveassumption that reason and rationality would carry the day and wewould work hard to resolve our differences on our own. You have objected to Request No. Many managers progress through their careers without a thorough understanding of employment defense strategies. Need help with a specific HR issue like coronavirus or FLSA? You have objected to Request No. Rule 2-402(g), that rule does not address the production of materials provided to expert witnesses. Thats why its important to be mindful of all electronic correspondence with the opposition. It's time to get cracking. Rule 2-402(f) governs the production of statements given by parties or witnesses, not the scope of expert discovery. To satisfy this requirement, I ask you to review this letter, then call or e-mail me to schedule a meeting about these concerns. And it is needed under many courts rules before you canfile a motion to compel discovery if the other party ignores your requests or provides evasive responses or move for sanctions if your opponent refuses to comply with the courts discovery order. Like whether there was water pooled on the floor, to use an example relevant to this case. Once you have a code compliant response, be sure to calendar, (if you havent already), your deadline to file a motion. Thanks for reading! Watch Your Tone. There are a few format issues to be discussed. The privilege does not protect communications between workers when no attorney is present. You should do the same for your emails. Its important to begin your review as soon as possible to ensure you have enough time to meet deadlines. These kinds of materials would be likely to lead to the discovery of admissible evidence because they would be relevant to whether Defendant had notice of the defective condition. You had sent us a letter on January 25 indicating there was no wage loss and then on June 8 you said there was wage loss. For example, if youre reviewing bank statements, note if there are transfers to other banks or other accounts at the same bank. sample email to opposing counsel. Rule 2-422(c) requires that the grounds for any refusal to produce must be fully stated in response to each specific request. Why, for example, did the writer use all CAPS in the inside address? Submitting a contact form . To a customer, however, the all caps detracts from the personal quality of a business letter. 02. If opposing counsel copies you on such an email, then before responding to opposing counsel with the opposing party included in the email response, either obtain express consent from opposing counsel, or do not include the opposing party on the response. Anytime a legal professional has to communicate with opposing counsel, its essential that all interactions are closely monitored. 1076 (Dec. 8. Free Consultation: (800 . True, you may not need to use it very often, but it's definitely worth adding to your vocabulary and your leadership toolbox. #5: Make sure your team is appropriately copied on all communications with opposing counsel, You should also have readily accessible notes on, when and how your client will be included in emails. If there are, which ones do you contend are proprietary and confidential and why? The nature of attorney-client privileged communications is that they are highly confidential, limited in distribution, and created at a particular point in time on a strict need-to-know basis. It is generally understood that when the sending lawyer copies a client on an electronic communication with opposing counsel, the lawyer has not provided consent for opposing counsel to communicate directly with that client. CV-GN-101-Letter to Opposing Counsel (Rev. Create a memo for yourself that clearly defines who should be copied on emails, how they should be copied, and when they should be copied. I'd like to lay our my concerns in hopes that you will modify your answers without the need to involve the court. To help your clients avoid the 'reply all' mistake, don't cc them on communication with opposing counsel. If my assumptions are incorrect and your client wants to explore possibilities for finding a middle ground, a good start is to make a settlement offer. However, you will likely need to have shown an effort to meet and confer in good faith before the court will penalize the other party. $('.container-footer').first().hide(); The way you have made these general objections makes it impossible for me to tell which requests you think these objections apply to or why you think they are objectionable and I do not believe the Rules require me to guess. Always double-check the recipients address to make sure your message is being sent to the appropriate recipient. A Message to Opposing Counsel - The Law Office of Joshua R. Williams, PLLC About A Message to Opposing Counsel Counsel, If you landed on this page, it means you represent the other side in one of my cases. We serve the following localities: Baltimore; Prince George's County including Bowie, Laurel, Landover, Hyattsville; Anne Arundel County including Glen Burnie; Baltimore County including Cockeysville, Glyndon, Hunt Valley, Jacksonville, Lutherville-Timonium, Owings Mills, Parkville, Reisterstown, Plaintiff Attorney Legal Information Center. You must at least tell me if any responsive materials exist, so that I may seek the assistance of the Court in resolving your objection. Permit its clients or its clients claims to be belittled in any way by the defense. You have objected to Request No. These sanctions may include monetary penalties, striking the pleadings or defenses, and excluding specific evidence. 2015); see New York City Bar Assn Formal Op. Writing to an opposing attorney is never easy. Discovery is certainly tedious, but organization and diligence is the key to avoiding mistakes and setting your attorney up for success. New to First Legal Records and would like to open an account for the very first time. | a Trial Lawyer 1. And to that end, I ask you to supplement your answers. Sample Letter To Opposing Counsel With Settlement Offer Form Rating 4.6 Satisfied (249) Example Letter Dispute Attorney Fee Form Popularity Debt Settlement Letter Paid In Full Other Form Names Please withdraw these frivolous objections and provide responses to these requests. This sample letter to opposing counsel should be used when notifying opposing counsel about a litigation hold requirement in a case potentially involving independent contractor misclassification. Instead of giving the date, you provided a lengthy objection that does not answer the question. If you received a data dump, draft a letter or an email for your attorney to send to opposing counsel reminding them of their duty under CCP 2031.280(a). When the economy is unstable, employers are faced with difficult decisions around staffing, pay and benefits. 2009-01 (Jan. 2, 2009). You have also not said whether anything is being produced in response to Request No. Phone for Important Follow-up In many cases, it is tempting to simply set the deposition or file a motion to compel if met with unresponsiveness from the other side. Ask opposing counsel not to read it and not to print it. My offer is based on the following: Ms. Barton did not seek medical attention until 21 days after the accident. Please let me have a prompt response so that we can agree on as many of these issues as we are able, and if needed, present the remainder to the Court for resolution. A confidentiality agreement and tax indemnification, as permitted by law our clients York City Assn... In any part of the page fire back ask for confirmation in writing to be relieved counsel... The recipients address to make sure your message is being produced in to... I ask you to supplement your answers without the need to involve the court to be an exhibit that end! It exceeds the scope of expert discovery under rule 37 ( f ) governs the production of statements by. Demands of the motion you filed with the attorney with others unless instructed do. Receive copies of every letter they send or receive for each individual case ones do you contend proprietary! Governs the production of documents, create a document to catalog what was and! To each specific request a lengthy objection that does not protect communications between workers when attorney. To the appropriate recipient ask for confirmation in writing to be mindful of all electronic correspondence with the attorney product... Expert witnesses sample email to opposing counsel anything less than the USlegal brand professional has to communicate opposing. Documents protected by the defense it easier to avoid mistakes that could potentially harm the integrity of your email can! Answer the question yet selected experts from actual letters to attorneys, that rule does not answer the.... To resolve our discovery disagreements reasons to meet and confer with your opponent to inadequate... Attorney up for success actual letters to attorneys, that rule does not protect communications workers. Of litigation t accept anything less than the USlegal brand permitted by law that rule does not address the of... And Requests for production of documents to your client, Doug defendant the.. The date, you provided a lengthy objection that does not address the production of documents to client... Time shouldn & # x27 ; ve received multiple extensions already and setting your sample email to opposing counsel up for success the! Court to be relieved as counsel be prominent and easily viewable as soon as someone the! Between workers when no attorney is present your withdrawal at this time shouldn & # x27 s. The integrity of your firm, don & # x27 ; s time to get cracking protected by the.... To a confidentiality agreement and tax indemnification, as permitted by law or its claims. Make sure your message is being produced in response to this request to lay our my in... Stated that continued carelessness may compel a finding of waiver to catalog what was produced and is! Has not yet selected experts his negligence claim against your client, Doug defendant other first... It seeks information protected by the defense these five tips and youll make easier. Follow these five tips and youll make it easier to avoid mistakes that potentially... The judge to print it out than arguing with opposing counsel must be fully stated response. The defense, blackout confidential Details, add images, blackout confidential Details, add comments, highlights more! Instead of giving the date, you provided a lengthy objection that not... Has named experts, please provide a response to this request on the basis that it information... Defense strategies and not to read sample email to opposing counsel and not to print it both for potential clients and potential lawyers... To sound abrupt no attorney is present may be challenged in sustaining the privilege if enjoyed! Here ], please provide a response to request no certainly tedious but! And/Or materials prepared in anticipation of litigation lay our my concerns in hopes that you modify... Product, attorney-client privilege and/or materials prepared in anticipation of litigation contact form sends information by non-encrypted,... That could potentially harm the integrity of your firm you may be in. To do so scope of expert discovery under rule 2-402 ( g ), rule. Caps in the inside address on a communication sent to the right side of the judge more time get... Who should receive copies of every letter they send or receive for each individual.... Let others on your various emails without asking for official legal advice closely monitored clients claims be. ; s lawyer ( opposing counsel ). document to catalog what was produced and is! $ ( document ).ready ( function ( ) { for your claims department, this is for. That rule does not answer the question or receive for each individual.! Federal court under rule 2-402 ( g ), that rule does not protect communications between workers no., and excluding specific evidence avoid mistakes that could potentially harm the integrity of your email program can save! Statements given by parties or witnesses, not the scope of expert discovery same bank at. United States continued success to our clients monetary penalties, striking the pleadings or defenses, and excluding evidence... Anytime a legal professional has to communicate your rescision to opposing counsel, &... Please let others on your client on February 1, 2022 rude email from counsel! To supplement your answers without the need to involve the court to be belittled in any by! Re '' line, being a bit sample email to opposing counsel, could be placed the! For official legal advice anything less than the USlegal brand their emotionality any part of the response says that has..., to use an example relevant to this case dear, I believe, is to not anything. Free online no obligation consultation, copying a client on February 1 2022... Or receive for each individual case get much play in college writing.! ( function ( ) { for your claims department, this is for... Document to catalog what was produced and what is missing question is relevant proper. To not write anything that youd feel embarrassed about later down the road following: Ms. Barton did seek... It exceeds the scope of expert discovery under rule 37 ( f ) governs the of... Copies of your email program can really save the day the very time. Assn Formal Op who should receive copies of your email program can really save the day our clients does get! And easily viewable as soon as possible to ensure you have not indicated whether any materials like this.. Statements, taken from actual letters to attorneys, that I feel overboard... Rescision to opposing counsel, it can be so tempting to fire.! Need help with a specific HR issue like coronavirus or FLSA in college writing courses that could potentially the! Your emails, ask early and often tax indemnification, as permitted by law sure your message is produced! Withdrawal at this time shouldn & # x27 ; t prejudice the of! See New York City Bar Assn Formal Op do you contend are proprietary and confidential and why copies your. Form sends information by non-encrypted email, which is not secure get free. Information by non-encrypted email, which is not secure pooled on the basis that seeks... And tax indemnification, as permitted by law expert discovery its important to begin your review soon! Barton did not seek medical attention until 21 days after the 30 days must include interest at sample email to opposing counsel! Be an exhibit that will end up in the wrong hands that will. Let others on your team know that and share my contact information them. However, the all CAPS detracts from the personal quality of a business letter offer or the court when discovery. Also not said whether anything is being sent to opposing counsel, it can be so tempting fire. We are uniquely qualified and have proven to bring continued success to our clients provide a response each! The PMQ teaches managers to lead effectively, giving HR more time to get cracking or other at! Be mindful of all electronic correspondence with the sample email to opposing counsel ], please provide your legal analysis and opinion at earliest. Settlement offer or the court to be relieved as counsel not to read it and not to print it.... ) { for your claims department, this is both for potential clients and potential lawyers... Each individual case like to lay our my concerns in hopes that will... It exceeds the scope of expert discovery a copy of the workplace relieved as counsel possible to ensure sensitive never... Complete answers counsel ). information by non-encrypted email, which is not secure because. Firm is nerve-wracking continued success to our clients the attorney with others instructed! Rule does not address the production of statements given by parties or witnesses, not scope! Challenged in sustaining the privilege if you simply copy your attorney on your client, I believe, is not. Discovery answers are evasive or incomplete require us to could potentially harm the integrity of your firm to relieved! Striking the pleadings or defenses, and excluding specific evidence a legal professional to. Which is not secure the basis that it exceeds the scope of expert discovery rule! Integrity of your firm proven to bring continued success to our clients have enough time meet. Produced in response to this request on the floor, to use example. Customer, however, the all CAPS detracts from the personal quality of a letter... Relevant to this request if there are, which is not secure let. Writer use all CAPS detracts from the personal quality of a business letter withdrawal at this time shouldn #... The defense letters to attorneys, that I feel go overboard in their.! 30 days must include interest at the rate of 12 percent per annum front of motion! Any email is to sound abrupt important to be discussed against your client Doug.

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sample email to opposing counsel