What is the proper written method to request or demand extension of time for request to produce documents?

Question

What is the proper written method to request or demand extension of time to produce documents not easily available for response to interrogatories and or production of documents? LA County. Med records are in other country and need to be translated, how to proceed extension of time request with court when dealing with potentially hostile opposing counsel?

Dan Rowan Cortright · Answer

You can request by email or letter to the opposing counsel the extension you need; the request is not sent to the court.

Brett Christopher Drouet · Answer

Requesting an extension to respond to a request for production of documents or interrogatories is an informal matter. As a good practice, you should seek the extension in a writing via email or fax. An example would be, as follows: 
 
"Dear Counsel, 
 
I am requesting a [state # days or weeks, etc..] to serve a response to [insert name of discovery propounding on my client [name] by your client [name].  As such, my client's response would be due on [insert date].   
 
Kindly please confirm your gracious extension. 
 
Thank you in advance for your anticipated and very much appreciated cooperation and courtesy." 
 
You need to make sure you obtain a confirmation from the opposing counsel, which confirms the requested extension.

James R. Dickinson · Answer

Mr. Drouet has given a great answer. [I litigate cases. Anything posted here must not be construed as legal advice, nor as grounds for forming an attorney-client relationship. You should seek an attorney for formal legal advice and representation.]

Q: What is the proper written method to request or demand extension of time for request to produce documents?