please edit the below reply letter as if a barrister would to comply with a discovery court order

Question

Dear Sirs,

I refer to your recent letter dated XXX and your prior letters dated XXX, XXX, XXX and my prior letters dated XXX and XXX.

I want to re-iterate that there is no legal basis to refuse my prior offers to produce the documents to comply with the Judgement Order attached at either the Company Secretary JW Office or at CRS's office if you agreed. This specific accomodation was provide because the registered office is as you and your client are aware is a residence where myself and children also live.

Nevertheless, I have agreed to accomodate your request to inspect the documents at the Company's Registered Office, which only serves to save our costs and time and increase your clients cost upon your request. I again refute your prior correspondences allegations but rather than debate have been repeatedly have been in good fail trying to comply with and fulfill the attached order.

I will make the documents available for your inspection to fulfil the attached order in a designated room of the Company's Registered office. I will make available all materials for inpection in either hard copy or digital in the designated inspection room.

As you requested dates after May 20, 2024 and I provide them below.
XXX
XXX
XXX

For the avoidance of any doubts, CRS nor your client are not entitled to have your personal IT person inspect all electronic devices or extract any information. I believe this is an attempted abuse of the order and if your client and firm persist with this demand or bring any foreign IT person attempting to access or extract any of the company's or my personal electronic devices this will be strictly prohibited.

Please confirm which dates/times as outlined above work best for your firm conduct its inspection to comply with the attached order.

Answer 1

Dear Sirs,

I acknowledge receipt of your recent letter dated XXX, as well as your prior letters dated XXX, XXX, and XXX, in addition to my prior letters dated XXX and XXX.

I wish to reiterate that there is no legal justification for rejecting my previous offers to produce the necessary documents in order to comply with the Judgement Order. These documents can be made available for inspection either at the Company Secretary JW Office or at CRS's office, provided that you agree to this arrangement. It is important to note that the Company's Registered Office is also a residence where I and my children reside.

Despite this, I am willing to accommodate your request to inspect the documents at the Company's Registered Office. This decision was made in an effort to streamline the process and minimize costs, while simultaneously increasing the expenses incurred by your client at your request. I categorically deny the allegations raised in your previous communications, and instead of engaging in a debate, I have consistently made good faith efforts to comply with the attached order.

I hereby confirm that the documents will be made available for inspection in a designated room at the Company's Registered Office, either in hard copy or digital format. As per your request, I am proposing the following dates for the inspection:

XXX
XXX
XXX

It is important to clarify that neither CRS nor your client is entitled to have any personal IT personnel inspect or extract information from any electronic devices. I believe that such a request constitutes an abuse of the order, and I am strictly prohibiting any attempts to access or extract data from the company's or my personal electronic devices by any foreign IT personnel.

Please confirm which of the proposed dates and times mentioned above would be suitable for your firm to conduct the inspection in order to comply with the attached order.

Yours faithfully,

[Your Name]
[Your Title/Barrister]