[Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] [Recipient's Name] [Recipient's Position] [Law Firm Name] [Address] [City, State, ZIP] Subject: Drafts of Joint Motion for Additional Discovery and Order Approving Same Dear [Recipient's Name], I hope this letter finds you well. I am writing to provide you with drafts of the Joint Motion for Additional Discovery and the Order Approving Same in the [case name] pending in [court name]. These drafts have been prepared in collaboration with [opposing party's name] in an effort to facilitate a smooth and efficient discovery process. The purpose of this motion is to request permission from the court to conduct additional discovery beyond the initial scope outlined in the discovery plan. Our need for this additional discovery arises due to [explanation of the reason(s) requiring additional discovery]. In order to fully present our respective positions and ensure a fair and just trial, it is imperative that we have the opportunity to explore the relevant facts and gather necessary evidence through this additional discovery. We have carefully reviewed the local rules of discovery and relevant case law in Alaska to ensure compliance with all procedural requirements. The attached drafts of the Joint Motion for Additional Discovery and the Order Approving Same have been prepared in accordance with these rules and take into account any specific requirements set forth by the court. Types of Alaska Sample Letters for Drafts of a Joint Motion for Additional Discovery and an Order Approving Same: 1. Joint Motion for Additional Discovery: This document outlines the details of the requested additional discovery, including the specific areas or witnesses to be explored, the proposed methods (e.g., interrogatories, depositions, requests for production of documents), and the anticipated timeline. It also highlights the justifications for the need of this additional discovery and demonstrates that it is proportionate, necessary, and would not cause undue burden or delay. 2. Order Approving Additional Discovery: This document seeks the court's approval of the joint motion for additional discovery. It lays out the reasons supporting the need for additional discovery, explains how it will not unduly delay the proceedings, and addresses any potential objections or concerns from the opposing party. The order also specifies the time frame, conditions, and any limitations imposed on the additional discovery. I kindly request that you carefully review these drafts and provide any feedback or suggested amendments. We believe that the proposed motion and order accurately reflect the requirements of Alaska's discovery laws and the particular circumstances of this case. However, we are open to constructive input to ensure that the documents best serve the interests of both parties and meet the court's expectations. Please let me know if you have any questions or if there is any additional information that you require. I am available at your convenience to discuss this matter further. Thank you for your attention to this important issue, and I look forward to your prompt response. Sincerely, [Your Name]