When it's used
After receiving deficient or objection-heavy discovery responses and before filing any motion to compel.
Definition
A meet-and-confer letter is the formal written correspondence that California CCP §2016.040 requires before a party may file a motion to compel further discovery responses, documenting that counsel made a genuine, good-faith effort to resolve the dispute informally. The letter identifies each deficient response by number, explains why the response is inadequate, states the specific additional information or documents sought, and sets a reasonable deadline for the opposing party to supplement or provide a substantive response. The paralegal drafts the letter with reference to the relevant statutes and specific interrogatory or RFP numbers, attaches the prior responses for easy reference, and sends it via a method that creates a proof of service. If the meet-and-confer fails, the letter and any response to it become exhibits to the motion to compel and are scrutinized by the court to assess whether the moving party acted in good faith.