Connecticut 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. Subject: Connecticut — Sample Letter for Joint Motion of Entry of Second Amended Scheduling Order Dear [Recipient's Name], I hope this letter finds you in good health. I am writing to submit a joint motion for the entry of a second amended scheduling order in the matter of [Case Name/Number]. In order to ensure smooth proceedings, we kindly request your cooperation and prompt action on this matter. As you are aware, the original scheduling order was established on [date] to set the timeline and deadlines for various stages of the litigation process. However, unforeseen circumstances have arisen that necessitate modifications to the existing order. This joint motion seeks to amend the scheduling order to reflect the changes required to accommodate both parties' schedules and ensure a fair and efficient resolution of the case. Attached to this letter, you will find a proposed second amended scheduling order that outlines the revised timeline and deadlines for the case. Our intention is to present an equitable and reasonable plan that takes into consideration the needs and constraints of both parties, and the court's availability and constraints. The proposed second amended scheduling order includes, but is not limited to: 1. Revised discovery deadlines: This outlines the revised dates for all discovery-related activities, such as the completion of written interrogatories, document production, and depositions for both plaintiff and defendant. 2. Expert witness deadlines: This section stipulates the dates by which each party must disclose their expert witnesses, exchange reports, and complete any related depositions or examinations. 3. Motion filing and hearing deadlines: We have adjusted the deadlines for filing any motions, briefs, or responses, as well as proposed dates for hearings and court appearances. 4. Pretrial conference and trial dates: Given the requested modifications, we have proposed new dates for the pretrial conference and the trial itself, considering the availability of all parties involved. It is essential that both parties promptly review the proposed second amended scheduling order and provide any necessary feedback or changes within [specified time frame], preferably through mutual consultation and negotiation. Our goal is to finalize the revised plan at the earliest convenience, avoiding unnecessary delays in the case. Please consider the importance of this matter and communicate your response by [deadline date]. We are confident that through collaboration and cooperation, we can achieve a mutually agreeable amended scheduling order that meets the needs of all parties involved. Thank you for your attention and prompt action in this regard. Should you have any questions or require further clarification, please do not hesitate to contact me directly at [your contact information]. Yours faithfully, [Your Name] [Your Title/Organization]

Subject: Connecticut — Sample Letter for Joint Motion of Entry of Second Amended Scheduling Order Dear [Recipient's Name], I hope this letter finds you in good health. I am writing to submit a joint motion for the entry of a second amended scheduling order in the matter of [Case Name/Number]. In order to ensure smooth proceedings, we kindly request your cooperation and prompt action on this matter. As you are aware, the original scheduling order was established on [date] to set the timeline and deadlines for various stages of the litigation process. However, unforeseen circumstances have arisen that necessitate modifications to the existing order. This joint motion seeks to amend the scheduling order to reflect the changes required to accommodate both parties' schedules and ensure a fair and efficient resolution of the case. Attached to this letter, you will find a proposed second amended scheduling order that outlines the revised timeline and deadlines for the case. Our intention is to present an equitable and reasonable plan that takes into consideration the needs and constraints of both parties, and the court's availability and constraints. The proposed second amended scheduling order includes, but is not limited to: 1. Revised discovery deadlines: This outlines the revised dates for all discovery-related activities, such as the completion of written interrogatories, document production, and depositions for both plaintiff and defendant. 2. Expert witness deadlines: This section stipulates the dates by which each party must disclose their expert witnesses, exchange reports, and complete any related depositions or examinations. 3. Motion filing and hearing deadlines: We have adjusted the deadlines for filing any motions, briefs, or responses, as well as proposed dates for hearings and court appearances. 4. Pretrial conference and trial dates: Given the requested modifications, we have proposed new dates for the pretrial conference and the trial itself, considering the availability of all parties involved. It is essential that both parties promptly review the proposed second amended scheduling order and provide any necessary feedback or changes within [specified time frame], preferably through mutual consultation and negotiation. Our goal is to finalize the revised plan at the earliest convenience, avoiding unnecessary delays in the case. Please consider the importance of this matter and communicate your response by [deadline date]. We are confident that through collaboration and cooperation, we can achieve a mutually agreeable amended scheduling order that meets the needs of all parties involved. Thank you for your attention and prompt action in this regard. Should you have any questions or require further clarification, please do not hesitate to contact me directly at [your contact information]. Yours faithfully, [Your Name] [Your Title/Organization]