[Your Name] [Your Address] [City, State, ZIP] [Date] [Recipient's Name] [Recipient's Address] [City, State, ZIP] Subject: Joint Motion for Additional Discovery and Order Approving Same in the Matter of [Case Name] Dear [Recipient's Name], I hope this letter finds you in good health and spirits. I am writing to you on behalf of all parties involved in the above-mentioned case to submit our joint motion for additional discovery and respectfully request an order approving the same. As you are aware, the [Case Name] is currently pending before the [Court Name] in Nassau County, New York. The purpose of this joint motion is to seek permission to conduct further discovery proceedings to ensure a fair and just resolution to the case. We firmly believe that the additional discovery outlined in this motion will contribute to a more comprehensive understanding of the facts at hand, facilitate equitable decision-making, and promote the efficient administration of justice. The proposed additional discovery sought by this joint motion includes the following: 1. Interrogatories: We request permission to submit a set of interrogatories to the opposing party(IES) within [specific time frame]. These written questions will delve into various aspects of the case, thereby enabling us to gather crucial information that may not have been previously disclosed. 2. Depositions: We seek leave to conduct depositions of key witnesses, experts, and relevant parties who possess significant knowledge or involvement in the matter. These depositions would provide an opportunity for both sides to examine and cross-examine witnesses under oath, allowing for a more thorough exploration of the issues. 3. Document Requests: We propose the exchange of specified document requests between the parties. These requests will seek relevant documents, records, and evidence necessary for a complete understanding of the case. Proper document production will enable us to evaluate the strength of our respective positions and aid in preparation for trial. In making this joint motion, all parties involved attest to the necessity and reasonableness of the additional discovery sought. We believe that the information obtained through this process will not only assist in the just resolution of the current dispute but also reduce the likelihood of future litigation or prolongation of the existing proceedings. We kindly request that the Honorable [Judge's Name] review our joint motion for additional discovery and grant an order approving the same. Enclosed with this letter, you will find the draft joint motion and proposed order for your convenience. Thank you for your attention to this matter. We eagerly await your favorable response and will be available to provide any additional information or address any concerns that may arise. Yours sincerely, [Your Name]