This form is a sample letter in Word format covering the subject matter of the title of the form.
[Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] [Recipient's Name] [Recipient's Address] [City, State, ZIP] Re: Joint Motion for Leave to Propound Additional Discovery in the Delaware Court Dear [Recipient's Name], I hope this letter finds you well. I am writing to formally submit the Joint Motion for Leave to Propound Additional Discovery on behalf of [Your Party's Name] and [Joint Party's Name]. As per the rules of the Delaware Court, we kindly request permission to pursue additional discovery in our ongoing case [Case Name/Number]. The purpose of this letter is to outline the specific details of our joint motion and emphasize the necessity of obtaining further information in order to facilitate a fair and just resolution. We believe that the additional discovery requests, described below, are crucial to uncovering essential facts, clarifying ambiguities, and ensuring that all parties have access to relevant evidence. Attached herewith, please find the proposed Joint Motion for Leave to Propound Additional Discovery, which consists of the following sections: 1. Introduction: This section provides a brief overview of the case and the reasons why our motion for additional discovery is essential for a comprehensive understanding of the matter. 2. Parties' Agreement: In this section, we emphasize the joint nature of this motion, indicating that all parties involved have collectively agreed upon the necessity of obtaining additional discovery. 3. Additional Discovery Requests: Here, we list the specific items and information we seek to obtain. These may include, but are not limited to, financial records, correspondence, contracts, expert reports, depositions, and any other relevant documents or evidence. 4. Relevance and Materiality: This section explains how the requested additional discovery is directly related to the central issues of the case, ensuring that no important facts remain concealed. 5. Scope and Timeframe: Here, we outline the proposed scope and timeframe for conducting the additional discovery, highlighting our commitment to complete the process in a diligent and efficient manner. 6. Parties' Cooperation: We express our intent to cooperate fully with all parties and the court during the additional discovery phase, including facilitating depositions, sharing information promptly, and addressing any concerns or objections promptly and fairly. 7. Confidentiality and Protective Order: If necessary, this section addresses any potential issues related to the confidentiality of sensitive information, outlining our commitment to adhere to any agreed-upon protective order or any relevant provisions mandated by the court. 8. Conclusion: We conclude the joint motion by respectfully requesting the court's permission to proceed with the additional discovery detailed in this letter. We express our appreciation for the court's attention to this matter and assure that we will comply with any orders or guidelines set forth. We believe that the additional discovery outlined in the Joint Motion is crucial for a fair determination of the facts and the just resolution of the case at hand. Furthermore, we trust that the court will consider our motion favorably, allowing us to obtain the necessary information to present our arguments effectively and accurately. Thank you for your attention to this matter. Should you require any additional information or documentation, please do not hesitate to contact me at [Phone Number] or [Email Address]. We appreciate your prompt consideration of our Joint Motion for Leave to Propound Additional Discovery. Sincerely, [Your Name] [Your Party's Name]
[Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] [Recipient's Name] [Recipient's Address] [City, State, ZIP] Re: Joint Motion for Leave to Propound Additional Discovery in the Delaware Court Dear [Recipient's Name], I hope this letter finds you well. I am writing to formally submit the Joint Motion for Leave to Propound Additional Discovery on behalf of [Your Party's Name] and [Joint Party's Name]. As per the rules of the Delaware Court, we kindly request permission to pursue additional discovery in our ongoing case [Case Name/Number]. The purpose of this letter is to outline the specific details of our joint motion and emphasize the necessity of obtaining further information in order to facilitate a fair and just resolution. We believe that the additional discovery requests, described below, are crucial to uncovering essential facts, clarifying ambiguities, and ensuring that all parties have access to relevant evidence. Attached herewith, please find the proposed Joint Motion for Leave to Propound Additional Discovery, which consists of the following sections: 1. Introduction: This section provides a brief overview of the case and the reasons why our motion for additional discovery is essential for a comprehensive understanding of the matter. 2. Parties' Agreement: In this section, we emphasize the joint nature of this motion, indicating that all parties involved have collectively agreed upon the necessity of obtaining additional discovery. 3. Additional Discovery Requests: Here, we list the specific items and information we seek to obtain. These may include, but are not limited to, financial records, correspondence, contracts, expert reports, depositions, and any other relevant documents or evidence. 4. Relevance and Materiality: This section explains how the requested additional discovery is directly related to the central issues of the case, ensuring that no important facts remain concealed. 5. Scope and Timeframe: Here, we outline the proposed scope and timeframe for conducting the additional discovery, highlighting our commitment to complete the process in a diligent and efficient manner. 6. Parties' Cooperation: We express our intent to cooperate fully with all parties and the court during the additional discovery phase, including facilitating depositions, sharing information promptly, and addressing any concerns or objections promptly and fairly. 7. Confidentiality and Protective Order: If necessary, this section addresses any potential issues related to the confidentiality of sensitive information, outlining our commitment to adhere to any agreed-upon protective order or any relevant provisions mandated by the court. 8. Conclusion: We conclude the joint motion by respectfully requesting the court's permission to proceed with the additional discovery detailed in this letter. We express our appreciation for the court's attention to this matter and assure that we will comply with any orders or guidelines set forth. We believe that the additional discovery outlined in the Joint Motion is crucial for a fair determination of the facts and the just resolution of the case at hand. Furthermore, we trust that the court will consider our motion favorably, allowing us to obtain the necessary information to present our arguments effectively and accurately. Thank you for your attention to this matter. Should you require any additional information or documentation, please do not hesitate to contact me at [Phone Number] or [Email Address]. We appreciate your prompt consideration of our Joint Motion for Leave to Propound Additional Discovery. Sincerely, [Your Name] [Your Party's Name]