[FIRM LETTERHEAD OR CAPTION BLOCK]
[DATE]
[Opposing Counsel Name]
[Law Firm]
[Address]
Via [Email/ECF/Overnight Mail]
Re: [Case Name], [Court], Case No. [Number] - Discovery Deficiency Meet-and-Confer
Counsel:
We write pursuant to Illinois Supreme Court Rules 201-219 to address deficiencies in your [responses/production] served on [DATE]. This letter documents our good faith effort to resolve this dispute before seeking court intervention under Ill. S. Ct. R. 219.
Illinois Discovery Rules - Key Citations
- Response deadlines: 28 days from service (Ill. S. Ct. R. 213(d), 214(c)); discovery must be completed within 6 months of defendant's appearance or within specified discovery plan
- Interrogatory limit: 30 interrogatories including all subparts (Ill. S. Ct. R. 213(c))
- Request for Production: Ill. S. Ct. R. 214; 28 days to respond
- Motion to compel (Ill. S. Ct. R. 219): Court may award expenses including attorney's fees for discovery abuse
- Sanctions (Ill. S. Ct. R. 219(c)): Includes striking pleadings, barring witnesses, monetary sanctions
- Cook County Local Rules: Additional requirements may apply in Cook County Circuit Court
Specific Deficiencies and Requested Cures
| No. | Request/Topic | Deficiency | Requested Cure | Deadline |
|---|---|---|---|---|
| 1 | [RFP No. __/Interrogatory No. __] | [e.g., improper objections; failure to produce documents per Ill. S. Ct. R. 214; inadequate interrogatory answers under R. 213] | [e.g., provide complete response; produce responsive documents; provide privilege log] | [Date] |
| 2 |
Additional Issues
- Privilege log (Ill. S. Ct. R. 201(n)): [not provided/incomplete]; Illinois requires a privilege log with sufficient detail to evaluate each claim—please provide by [DATE] with document date, author, recipients, privilege type, and general description.
- Verification: Interrogatory answers must be signed under oath (Ill. S. Ct. R. 213(d)).
- ESI/formatting: [missing metadata/native format]; please re-produce in [reasonably usable form per Ill. S. Ct. R. 214(a)].
- Protective order/clawback: [status]; propose to file agreed protective order by [DATE].
Illinois-Specific Sanctions Warning
Under Ill. S. Ct. R. 219(c), the court may impose sanctions including:
- Award of reasonable expenses including attorney's fees
- Barring testimony of witnesses not properly disclosed
- Striking pleadings or dismissal/default judgment
- Contempt of court
Illinois courts have increasingly imposed significant sanctions for discovery abuse and boilerplate objections.
Proposed Path to Resolution
- Meet-and-confer availability: [3 date/time windows] (Central Time). We are prepared to meet telephonically or in person.
- We propose resolving without court intervention if you confirm supplemental responses/production by [DATE].
- If unresolved by [DATE], we will file a motion to compel under Ill. S. Ct. R. 219 and seek fees and costs.
- We will reference this correspondence and our efforts to resolve the dispute informally.
Preservation Reminder
Please confirm litigation holds remain in place for email, text messages, messaging platforms, shared drives, cloud storage, and any custodian-specific data sources relevant to the disputed requests.
We look forward to your prompt response.
Sincerely,
______________________________
[Attorney Name]
[Law Firm]
Counsel for [Party]