[Your Name] [Your Address] [City, State, ZIP Code] [Email Address] [Phone Number] [Date] [Clerk's Name] [Court Name] [Court Address] [City, State, ZIP Code] Re: Joint Motion for Leave to Propound Additional Discovery Dear [Clerk's Name], I hope this letter finds you in good health and high spirits. I am writing to file a Joint Motion for Leave to Propound Additional Discovery in the case of [Case Name and Number] pending before this honorable court. As a joint request by the parties involved, we seek permission to propound additional discovery requests in order to explore crucial aspects of the case that have recently come to light. The parties to this litigation, [Plaintiff's Name] and [Defendant's Name], have reached the mutual understanding that further discovery is necessary in order to gain a comprehensive grasp of the facts and evidence pertaining to this matter. We firmly believe that the additional information we intend to seek will assist in ensuring a fair and just resolution of this case. It is essential to note that the requested additional discovery does not seek to unduly burden or delay the proceedings. On the contrary, it seeks only to obtain pertinent information that has a direct bearing on the material issues of this case. The discovery we aim to propound primarily includes: 1. Interrogatories: We request permission to submit additional written questions to the opposing party, seeking clarification on certain ambiguous statements made in their initial responses, as well as probing into newly discovered aspects of the case. 2. Requests for Production: We seek leave to request additional documents and pieces of evidence that have recently come to light or require further scrutiny. These documents are believed to hold substantial relevance to the core issues of this case. 3. Requests for Admission: We request permission to seek further admissions from the opposing party, specifically targeting recent developments that warrant clarification or confirmation. The parties have engaged in extensive discussions, and it has become evident that the additional discovery being sought is essential for a fair and just resolution of this matter. We affirm our commitment to comply with all applicable rules and guidelines governing discovery and assure you that our intentions are solely focused on serving the interests of justice in this case. Enclosed with this letter, you will find the Joint Motion for Leave to Propound Additional Discovery, which the parties have jointly prepared and signed. We kindly request that you file it with the court and initiate the necessary procedures for its consideration. Should any further documentation or information be required or if there are any other procedures that need to be followed, please do not hesitate to contact me at the provided phone number or email address. I appreciate your time and attention to this matter. Thank you for your prompt assistance in this regard. Sincerely, [Your Name]
[Your Name] [Your Address] [City, State, ZIP Code] [Email Address] [Phone Number] [Date] [Clerk's Name] [Court Name] [Court Address] [City, State, ZIP Code] Re: Joint Motion for Leave to Propound Additional Discovery Dear [Clerk's Name], I hope this letter finds you in good health and high spirits. I am writing to file a Joint Motion for Leave to Propound Additional Discovery in the case of [Case Name and Number] pending before this honorable court. As a joint request by the parties involved, we seek permission to propound additional discovery requests in order to explore crucial aspects of the case that have recently come to light. The parties to this litigation, [Plaintiff's Name] and [Defendant's Name], have reached the mutual understanding that further discovery is necessary in order to gain a comprehensive grasp of the facts and evidence pertaining to this matter. We firmly believe that the additional information we intend to seek will assist in ensuring a fair and just resolution of this case. It is essential to note that the requested additional discovery does not seek to unduly burden or delay the proceedings. On the contrary, it seeks only to obtain pertinent information that has a direct bearing on the material issues of this case. The discovery we aim to propound primarily includes: 1. Interrogatories: We request permission to submit additional written questions to the opposing party, seeking clarification on certain ambiguous statements made in their initial responses, as well as probing into newly discovered aspects of the case. 2. Requests for Production: We seek leave to request additional documents and pieces of evidence that have recently come to light or require further scrutiny. These documents are believed to hold substantial relevance to the core issues of this case. 3. Requests for Admission: We request permission to seek further admissions from the opposing party, specifically targeting recent developments that warrant clarification or confirmation. The parties have engaged in extensive discussions, and it has become evident that the additional discovery being sought is essential for a fair and just resolution of this matter. We affirm our commitment to comply with all applicable rules and guidelines governing discovery and assure you that our intentions are solely focused on serving the interests of justice in this case. Enclosed with this letter, you will find the Joint Motion for Leave to Propound Additional Discovery, which the parties have jointly prepared and signed. We kindly request that you file it with the court and initiate the necessary procedures for its consideration. Should any further documentation or information be required or if there are any other procedures that need to be followed, please do not hesitate to contact me at the provided phone number or email address. I appreciate your time and attention to this matter. Thank you for your prompt assistance in this regard. Sincerely, [Your Name]
