[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 the Alaska Rules of Civil Procedure discovery requirements (Rules 26-37) and applicable local rules to address deficiencies in your [responses/production] served on [DATE]. Please see the specific issues below and the cure we request.
Specific Deficiencies and Requested Cures
| No. | Request/Topic | Deficiency | Requested Cure | Deadline |
|---|---|---|---|---|
| 1 | [RFP/Interrogatory/Topic] | [e.g., objections only, no documents produced] | [e.g., produce responsive documents without boilerplate objections] | [Date] |
| 2 |
Additional issues:
- Privilege log: [not provided/incomplete]; please provide by [DATE] with custodians, date, authors, recipients, privilege basis, document type.
- ESI/formatting: [missing metadata/OCR/unsearchable]; please re-produce with [format].
- Protective order/clawback: [status], propose to file by [DATE].
Proposed Path to Resolution
- Availability for meet-and-confer: [3 date/time windows] (specify time zone).
- We propose resolving without court intervention if you confirm the above cures by [DATE].
- If unresolved, we intend to seek relief via [motion to compel/discovery conference] and will reference this letter.
Preservation Reminder
Please confirm preservation holds remain in place for email, shared drives, mobile messaging, cloud storage, and any third-party data sources relevant to the disputed requests.
We look forward to your prompt response.
Sincerely,
______________________________
[Attorney Name]
[Law Firm]
Counsel for [Party]
[// GUIDANCE: Alaska Civil Rule 37(a)(1) requires a certification of good faith meet-and-confer efforts before filing a motion to compel. Document your efforts thoroughly for any subsequent motion.]