Arkansas Sample Letter for Joint Motion of Entry of Second Amended Scheduling Order

• Category: Letters - Legal - Motions
• State: Multi-State
• Control #: US-0865LTR
• Format: Word; Rich Text

Description

This form is a sample letter in Word format covering the subject matter of the title of the form. Dear [Judge's Name], RE: Joint Motion of Entry of Second Amended Scheduling Order We, the undersigned parties [Party A] and [Party B], respectfully submit this joint motion for the entry of a Second Amended Scheduling Order in the above-mentioned case pending before this honorable court. We seek your approval for this motion due to the evolving circumstances that necessitate revised deadlines and a modified timeline. Our intention to jointly request this amendment arises from our mutual desire to ensure a fair and efficient progression of the case, while considering the best interests of all parties involved and promoting judicial economy. The current Scheduling Order, previously entered by this court on [date], served as a guide for the orderly and timely conduct of the case. However, unforeseen factors have emerged since its inception, including, but not limited to [provide relevant reasons]. These unforeseen factors necessitate the revision of existing deadlines and the introduction of additional steps to guarantee a comprehensive and just resolution. Specifically, the parties propose the following modifications to the initial Scheduling Order: 1. Amended Date for Discovery Completion: Due to the intricacies and complexities of this case, and to allow for thorough and diligent fact-finding, we propose extending the deadline for the completion of all discovery-related activities to [new date]. This extension is crucial to ensure a comprehensive exchange of information and the preservation of fairness in the proceedings. 2. Amended Date for Filing Motions: Recognizing the need to accommodate the additional time required for discovery, the parties propose an amended deadline for the filing of all motions to [new date]. This extension would enable us to fully assess the evidentiary record resulting from the revised discovery timeline before engaging in substantive legal arguments. 3. Amended Date for Expert Disclosures: Given the complexities involved and the necessity to secure expert opinions, we humbly request an extension for the deadline of exchanging expert disclosures to [new date]. This additional time will allow us to engage experts, conduct thorough analyses, and present well-formulated and substantiated reports. 4. Amended Date for Pretrial Conference: To facilitate the comprehensive preparation of the case and enhance its overall efficiency, we propose an amended date for the pretrial conference to [new date]. This extension will ensure that all parties are sufficiently equipped to engage in productive discussions and explore potential avenues for resolution. We emphasize that the proposed amended scheduling order serves the interests of all parties involved, as it provides ample time for discovery, expert consultations, legal research, and the potential for alternative dispute resolution. Therefore, we kindly request the court's approval of this joint motion for the entry of a Second Amended Scheduling Order, as outlined above, to allow us to best navigate the evolving circumstances of this case. Thank you for your attention to this matter. Yours sincerely, [Party A] [Party B]

Dear [Judge's Name], RE: Joint Motion of Entry of Second Amended Scheduling Order We, the undersigned parties [Party A] and [Party B], respectfully submit this joint motion for the entry of a Second Amended Scheduling Order in the above-mentioned case pending before this honorable court. We seek your approval for this motion due to the evolving circumstances that necessitate revised deadlines and a modified timeline. Our intention to jointly request this amendment arises from our mutual desire to ensure a fair and efficient progression of the case, while considering the best interests of all parties involved and promoting judicial economy. The current Scheduling Order, previously entered by this court on [date], served as a guide for the orderly and timely conduct of the case. However, unforeseen factors have emerged since its inception, including, but not limited to [provide relevant reasons]. These unforeseen factors necessitate the revision of existing deadlines and the introduction of additional steps to guarantee a comprehensive and just resolution. Specifically, the parties propose the following modifications to the initial Scheduling Order: 1. Amended Date for Discovery Completion: Due to the intricacies and complexities of this case, and to allow for thorough and diligent fact-finding, we propose extending the deadline for the completion of all discovery-related activities to [new date]. This extension is crucial to ensure a comprehensive exchange of information and the preservation of fairness in the proceedings. 2. Amended Date for Filing Motions: Recognizing the need to accommodate the additional time required for discovery, the parties propose an amended deadline for the filing of all motions to [new date]. This extension would enable us to fully assess the evidentiary record resulting from the revised discovery timeline before engaging in substantive legal arguments. 3. Amended Date for Expert Disclosures: Given the complexities involved and the necessity to secure expert opinions, we humbly request an extension for the deadline of exchanging expert disclosures to [new date]. This additional time will allow us to engage experts, conduct thorough analyses, and present well-formulated and substantiated reports. 4. Amended Date for Pretrial Conference: To facilitate the comprehensive preparation of the case and enhance its overall efficiency, we propose an amended date for the pretrial conference to [new date]. This extension will ensure that all parties are sufficiently equipped to engage in productive discussions and explore potential avenues for resolution. We emphasize that the proposed amended scheduling order serves the interests of all parties involved, as it provides ample time for discovery, expert consultations, legal research, and the potential for alternative dispute resolution. Therefore, we kindly request the court's approval of this joint motion for the entry of a Second Amended Scheduling Order, as outlined above, to allow us to best navigate the evolving circumstances of this case. Thank you for your attention to this matter. Yours sincerely, [Party A] [Party B]