Discovery Deficiency Letter
(PA)

This template can be used to address deficiencies in discovery responses in a Pennsylvania state court action. This template includes practical guidance, drafting notes, and optional clauses. In a letter regarding deficient discovery, state the nature of the deficiencies clearly and include a request for the missing information. If the deficiencies are not addressed, you may need to file a motion to compel. This letter would then become important evidence, showing that the opposing party was advised of the deficiencies and that you provided that other party with a good faith opportunity to resolve the issues without court intervention. For related templates, see Requests for Production of Documents and Things (RFPs) (Defendant to Plaintiff) (PA), Interrogatories: Drafting and Serving Interrogatories (PA), and Requests for Admission: Drafting and Serving RFAs (PA).