Discovery Deficiency Meet-and-Confer Letter - Wyoming

DISCOVERY DEFICIENCY MEET-AND-CONFER LETTER

[FIRM OR SENDER NAME]
[STREET ADDRESS]
[CITY, STATE ZIP]
[PHONE] · [EMAIL]

Date: [____________]

Delivery to counsel: [METHOD AND ADDRESS]

[OPPOSING COUNSEL NAME]
[FIRM NAME]
[ADDRESS]

Re: [CASE NAME], [COURT AND COUNTY], No. [CASE NUMBER]
Discovery at issue: [INTERROGATORIES / REQUESTS FOR PRODUCTION / REQUESTS FOR ADMISSION / INITIAL DISCLOSURES], served [DATE]; responses received [DATE]

Dear [COUNSEL NAME]:

I write for [PARTY] to confer in good faith about the specific discovery issues below. Wyoming Rule of Civil Procedure 37(a)(1) requires a motion to compel to include a certification that the movant conferred or attempted to confer in good faith to obtain the discovery without court action. Please discuss these issues with me by [DATE] at [PHONE OR EMAIL], or suggest another prompt time.

The requests and responses at issue are identified precisely below. Our requests remain subject to Rule 26(b)(1)'s relevance and proportionality limits and any applicable order or stipulation. The applicable response date was [DATE], calculated from service, any extension, and Rule 6(d)'s three added days if service was by mail.

For any interrogatory at issue, please address the unanswered portion separately and fully in writing under oath, or state a specific objection. Rule 33(b)(3)-(5). If relying on the business-record option, identify records in enough detail for us to locate them as readily as you can and provide a reasonable opportunity to inspect and copy them, as Rule 33(d) requires. Identify any dispute over the 25-interrogatory limit, including discrete subparts, and any stipulation or order. Rule 33(a)(1).

For any production request at issue, please state whether inspection or production will occur, or give specific grounds and reasons for an objection. Identify whether responsive material is withheld on that basis; for a partial objection, identify the affected part and permit inspection of the rest. State the intended ESI form if you object to a requested form or no form was specified. Rule 34(b)(2)(B)-(E).

For any privilege or trial-preparation protection claim, please expressly identify the claim and describe the nature of withheld material sufficiently for assessment without revealing protected content. Rule 26(b)(5)(A). If a response later became materially incomplete or incorrect and the corrective information has not otherwise been made known in discovery or in writing, please supplement it in a timely manner. Rule 26(e)(1).

For any admission request at issue, please identify whether a timely answer or objection was served. Rule 36(a)(3)-(6) governs the answer, any sufficiency motion, and the effect of no response. A matter admitted remains conclusively established unless the court permits withdrawal or amendment under Rule 36(b).

Our proposed resolution is: [SPECIFIC NARROWING, SEARCH OR PRODUCTION PLAN, VERIFIED ANSWER, OR CONFERENCE RESULT]. Please respond by [DATE], and propose times to confer: [OPTION 1] or [OPTION 2]. This requested date is for resolving the dispute; it does not amend a court deadline or waive an admission.

If we cannot resolve the stated issues, we may seek an order under Rule 37(a) and provide the required conference certification. Rule 37(a)(5) governs any motion expense award, including its exceptions and different results for granted, denied, or mixed motions. Further sanctions under Rule 37(b)(2) depend on disobedience of a discovery order.

Sincerely,

[ATTORNEY NAME]
[WYOMING BAR NUMBER]
Counsel for [PARTY]
[PHONE] · [EMAIL]

Attachments, if any: [REQUESTS / RESPONSES / CORRESPONDENCE]