The Meet-and-Confer Letter

Draft a meet-and-confer letter on a discovery dispute.

Dispute: [DESCRIBE THE DISAGREEMENT]
The requests or responses at issue: [PASTE OR DESCRIBE]
Our position: [DESCRIBE]
Their stated position: [DESCRIBE]
What resolution we want: [DESCRIBE]

Produce:
1. A letter that states the specific issues in dispute,
   itemised, not as a general grievance
2. For each item: what we asked, what we received, why it is
   deficient, and the specific relief we seek
3. A proposed narrowing or compromise for each, so the letter
   moves toward resolution rather than posturing
4. A clear request to confer, with proposed times
5. A record that we are attempting to resolve this in good
   faith before seeking court intervention
6. A firm but professional tone throughout — no rhetoric that
   will read badly if attached to a motion

Constraints:
- Do NOT cite any rule, case, or statute — insert [CITE]
  where a procedural reference belongs
- Do NOT assert what the rules require
- Nothing asserted that I have not supplied