[Your Name] [Your Address] [City, State, ZIP Code] [Email Address] [Phone Number] [Date] [Judge's Name] [Court Name] [Court Address] [City, State, ZIP Code] Re: [Case Number] Dear [Judge's Name], I am writing to submit a Joint Motion for Leave to Propound Additional Discovery in the above-mentioned case. I represent [Plaintiff's Name] along with their co-counsel [Defendant's Name]. According to the Colorado Rules of Civil Procedure (C.R.C.P.), specifically Rule 26, we request the Court's permission to conduct further discovery in order to properly prepare for trial. The purpose of our Joint Motion is to seek your approval for additional discovery that we believe is necessary to determine the facts surrounding this case. To provide a comprehensive insight into the case and facilitate fair judgment, we require [number of] additional interrogatories and [number of] requests for production of documents. We are confident that these inquiries and requests will provide crucial information, which will benefit all parties involved and aid in ensuring a just outcome. Although the discovery phase was completed on [prior deadline/date], recent circumstances and the emergence of new evidence have necessitated this Joint Motion for Leave to Propound Additional Discovery. We assure the Court that this motion is not intended to delay or harass any party, but rather to promote transparency and enhance the quality of evidence presented during the trial proceedings. If the Court grants our Joint Motion, we propose a reasonable timeline for the completion of these additional discovery efforts. We suggest setting a deadline of [proposed deadline/date] for the completion of all interrogatories and requests for production of documents. This timeline aligns with the schedule set forth by the Court and allows all parties ample time to respond to the additional discovery requests. Furthermore, we have forwarded a copy of this Joint Motion to opposing counsel, [Opposing Counsel's Name], and we have received their endorsement in pursuing this additional discovery. We hope this collaborative effort demonstrates our commitment to resolving this case in a fair and efficient manner. Enclosed with this letter, please find a copy of the Joint Motion for Leave to Propound Additional Discovery, which contains additional details and legal citations supporting our request. We kindly request that it be placed on the Court's docket at the earliest convenience. Thank you for your attention to this matter. We trust in the Court's wisdom to evaluate our Joint Motion fairly and impartially. Should the Court require any further information, please do not hesitate to contact me at [Your Phone Number] or via email at [Your Email Address]. Respectfully, [Your Name] [Attorney's Bar Number]
[Your Name] [Your Address] [City, State, ZIP Code] [Email Address] [Phone Number] [Date] [Judge's Name] [Court Name] [Court Address] [City, State, ZIP Code] Re: [Case Number] Dear [Judge's Name], I am writing to submit a Joint Motion for Leave to Propound Additional Discovery in the above-mentioned case. I represent [Plaintiff's Name] along with their co-counsel [Defendant's Name]. According to the Colorado Rules of Civil Procedure (C.R.C.P.), specifically Rule 26, we request the Court's permission to conduct further discovery in order to properly prepare for trial. The purpose of our Joint Motion is to seek your approval for additional discovery that we believe is necessary to determine the facts surrounding this case. To provide a comprehensive insight into the case and facilitate fair judgment, we require [number of] additional interrogatories and [number of] requests for production of documents. We are confident that these inquiries and requests will provide crucial information, which will benefit all parties involved and aid in ensuring a just outcome. Although the discovery phase was completed on [prior deadline/date], recent circumstances and the emergence of new evidence have necessitated this Joint Motion for Leave to Propound Additional Discovery. We assure the Court that this motion is not intended to delay or harass any party, but rather to promote transparency and enhance the quality of evidence presented during the trial proceedings. If the Court grants our Joint Motion, we propose a reasonable timeline for the completion of these additional discovery efforts. We suggest setting a deadline of [proposed deadline/date] for the completion of all interrogatories and requests for production of documents. This timeline aligns with the schedule set forth by the Court and allows all parties ample time to respond to the additional discovery requests. Furthermore, we have forwarded a copy of this Joint Motion to opposing counsel, [Opposing Counsel's Name], and we have received their endorsement in pursuing this additional discovery. We hope this collaborative effort demonstrates our commitment to resolving this case in a fair and efficient manner. Enclosed with this letter, please find a copy of the Joint Motion for Leave to Propound Additional Discovery, which contains additional details and legal citations supporting our request. We kindly request that it be placed on the Court's docket at the earliest convenience. Thank you for your attention to this matter. We trust in the Court's wisdom to evaluate our Joint Motion fairly and impartially. Should the Court require any further information, please do not hesitate to contact me at [Your Phone Number] or via email at [Your Email Address]. Respectfully, [Your Name] [Attorney's Bar Number]
