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Discovery and production

Prepare a meet-and-confer letter and record the exchange

A discovery response or production appears deficient, and the team needs a letter grounded in the request and a chronology of the ensuing exchange.

For firm teamsReviewed Available. The attorney selects the demand, cure-by date and applicable procedural requirements.

Before you begin

  • The relevant request, response and supporting production references.
  • An attorney to decide the asserted deficiency, requested cure and any date.

What to do

  1. Open the matter's Discovery area and Meet & confer for the relevant request. Read the existing chronology before opening another round. A failed history read means the prior exchange is unknown, so retry it before assuming this is the first communication.
  2. Review the deficiency checklist and select only items supported by the response or production. Add the request number, specific objection or missing material and the source reference. A suspected attachment gap should be described with its qualification if the underlying match remains unconfirmed.
  3. Prepare the letter and inspect its text. The letter uses the recorded deficiencies and attorney entries. Review each demand and remove language that exceeds the record. The attorney supplies the cure-by date; a placeholder must not be mistaken for a calculated legal deadline.
  4. Save the letter to the matter and open the resulting document for review. Use the required approval and sending process. Record the actual send and later response when they occur, rather than marking the exchange sent merely because a draft was created or copied.
  5. As the exchange develops, record the response and disposition against the same round. Use Save & copy compel record when preparing the chronology for further work, and inspect the saved document. The attorney must assess the applicable conference requirements and the sufficiency of the recorded history.

What you should see

The letter identifies specific supported deficiencies, and the matter contains a chronology that distinguishes drafting, sending, response and resolution.

Limits and unresolved problems

BRON does not decide whether the exchange satisfies a court's meet-and-confer requirement. A generated chronology records the entries supplied; it does not establish an unrecorded conversation or service event.

Product scope and requirements

Related guides

Still need a hand?

Record the screen, time, displayed status and steps you tried. Use your signed-in support route or contact your firm administrator. Do not include credentials or confidential documents in a public message.

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