skills/correspondence/references/synthetic-patterns.md

# Synthetic correspondence patterns

Every name, date, request, number, and fact below is fictional. These patterns are deliberately incomplete until a lawyer supplies the matter's record, governing order, client authority, and intended mechanics. They are drafting aids, not forms, and should remain in the outbox until the no-send gate is cleared.

## Synthetic discovery meet-and-confer

**Internal status:** `DISCOVERY CONFER — proposed deficiency letter; no conference represented as completed; NO SEND — lawyer approval required.`

**Subject:** [Matter / case number] — proposed resolution of RFP Nos. 7 and 9

Counsel:

We write to identify two discrete issues in [Responding Party]'s [date] responses to RFP Nos. 7 and 9 and to propose a call under [specific local rule or scheduling-order paragraph]. This letter is intended to focus a good-faith conference; it is not a motion and does not add a request.

For RFP No. 7, the request seeks [short exact description]. The response states [short exact response or objection], but does not state whether [defined custodian/date range/format] was searched or whether responsive, nonprivileged material exists. The production log identifies [source record], which appears to show [limited, qualified observation]. We are not asking for [agreed exclusion].

For RFP No. 9, the request seeks [short exact description]. We understand the objection to be [exact objection]. To narrow the issue, we propose [custodians], [date range], [fields or search terms], and production in [format], subject to [protective-order or confidentiality term]. If that remains disproportionate, please identify the burden and propose a narrower substitute.

Please confirm by [date, time, and time zone] whether you can confer by phone or video on [two proposed dates]. If we reach agreement, we will memorialize the agreed supplementation and date. If an issue remains genuinely unresolved after the conference, we will identify the specific impasse and the relief sought under the governing rule. We reserve positions on matters not addressed here without obscuring the two proposed cures.

Regards,

[Name / firm / contact information]

**Reviewer annotations:** Replace every bracket with the exact served request, response, source locator, rule, and proposed cure. Confirm whether a live conference is mandatory and whether a letter may be filed. Do not write “you have waived” unless the applicable law and record support that position. Do not state that counsel conferred until the call occurs; afterward add the date, participants, positions, agreements, and impasses from contemporaneous notes.

## Synthetic settlement demand

**Internal status:** `SETTLEMENT LIKELY — proposed demand; client authority and binding mechanics unresolved; NO SEND — lawyer approval required.`

**Subject:** [Matter / claim] — settlement proposal

Counsel:

Our client disputes [briefly identify the claim and the opposing position as reflected in the supplied record]. To explore resolution, our client proposes the following settlement, subject to a mutually executed writing: [amount or other consideration], paid by [date and method], in exchange for [release scope, released parties, excluded claims, dismissal, and other essential terms]. The proposal is intended to resolve [defined claims and period] and does not extend to [excluded claims or persons].

The proposal is based on [verified record or clearly labeled position: liability facts, damages categories, procedural cost, or other rationale]. We have not included privileged strategy. We do not represent that the factual disputes are resolved, and nothing in this proposal should be treated as an admission. The parties should confirm treatment of fees and costs, liens and taxes, confidentiality or public statement, non-disparagement, payment security, any required approval, and integration before execution.

This is a settlement communication concerning a claim disputed as to [validity and/or amount]. The parties should analyze the governing evidence rule and other applicable law for each later use; this heading does not create privilege or confidentiality. The proposal is intended to be nonbinding unless and until the parties execute the contemplated writing, but counsel must verify that the language, conduct, essential terms, and governing law actually make execution a condition to formation.

Please respond by [date, time, and time zone] through [authorized channel]. Silence is not acceptance. If you agree in principle, please identify any open term and confirm who has authority to approve the writing.

Regards,

[Name / firm / contact information]

**Reviewer annotations:** Confirm the claim is actually disputed, the amount and nonmonetary terms are authorized, and contract law supports the stated acceptance mechanics. Decide whether the client wants an offer capable of acceptance or a nonbinding proposal. Do not use a “without prejudice” label as a substitute for these decisions. Check whether the letter may affect jurisdiction, notice, insurance, reporting, or contractual deadlines.

## Synthetic response and counteroffer

**Internal status:** `SETTLEMENT RESPONSE — proposed counteroffer; further authority on releases and payment security required; NO SEND — lawyer approval required.`

**Subject:** Re: [Matter / claim] — response to [date] proposal

Counsel:

We acknowledge receipt of your [date] proposal. Our client accepts [identify any agreed process point] and does not accept [identify disputed liability or term]. Without resolving the factual disputes, our client is prepared to propose [counteroffer amount or relief], subject to [specific release, payment, approval, confidentiality, and dismissal terms].

For clarity, the material terms are: [payment amount and date]; [released and excluded claims and persons]; [dismissal or other performance]; [fees, costs, liens, taxes, and security]; [confidentiality or public statement, if authorized]; and [required approvals and signed-writing condition]. The proposal is intended to expire at [time, time zone] on [date] unless extended in writing by an authorized representative. It states that silence, partial performance, and continued discussion are not intended as acceptance, subject to counsel confirming that the offer language, later conduct, and governing law give those mechanics effect.

Please confirm whether the counteroffer is acceptable or identify a precise alternative. If you need additional information to evaluate [defined point], say what is needed and we will consider a focused exchange. We reserve all rights outside the proposal, subject to the applicable rules governing settlement communications and any executed agreement.

Regards,

[Name / firm / contact information]

**Reviewer annotations:** A response should address material terms one by one and distinguish accepted, rejected, and open items. “Final” is reserved for a client-authorized position with clear mechanics. Confirm the expiration time, authority, and whether continued negotiations modify or revoke the offer under applicable law. Keep privileged evaluation and unverified merits assertions out of the outbound draft.

## Synthetic substantive pre-suit notice

**Internal status:** `ORDINARY SUBSTANTIVE — proposed notice and preservation request; representation and procedural effect unresolved; NO SEND — lawyer approval required.`

**Subject:** [Matter] — preservation and response regarding [defined event]

Counsel:

We represent [client] concerning [defined event and date]. Based on [identified record], our client contends that [short, qualified position]. We request that you preserve documents and electronically stored information reasonably related to [custodians, systems, and date range], including relevant metadata, and that you confirm by [proposed date and time zone] whether a litigation hold or equivalent preservation step is in place.

This letter is not a settlement offer and does not waive any claim, defense, or procedural position. We request a substantive response concerning [defined action] by [date]. If you are represented in this matter, please direct communications through counsel. If you believe a different person or entity is the proper contact, identify that basis rather than forwarding client-confidential information.

Regards,

[Name / firm / contact information]

**Reviewer annotations:** Confirm representation and direct-contact restrictions before sending. Replace “reasonably related” with a defensible scope where possible, and check the governing law and any preservation order. State consequences only when the client is authorized and prepared to pursue them. Before mentioning criminal, disciplinary, or regulatory action, require a jurisdiction-specific professional-conduct, substantive-law, factual-basis, relationship, and improper-influence review; do not include a baseless, misleading, unlawful, or prohibited threat. Keep this document separate from any settlement proposal.