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Delaware Sample Letter to Clerk for filing Joint Motion for Leave to Propound Additional Discovery

State:
Multi-State
Control #:
US-0863LTR
Format:
Word; 
Rich Text
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Description

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] Clerk of the Court [Delaware Court Name] [Delaware Court Address] [City, State, ZIP] Re: Joint Motion for Leave to Propound Additional Discovery Case Name/Number: [Provide relevant case name and number] Dear Clerk, 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 aforementioned case. We kindly request the court's permission to expand the scope of discovery for the following reasons: 1. Background/Introduction: Provide a brief overview of the case, including the parties involved, the nature of the dispute, and any relevant background information. 2. Discovery Status: Briefly summarize the current discovery process, including the type and extent of discovery already propounded by both parties. 3. Purpose and Relevance of Additional Discovery: Clearly state the purpose and relevance of the proposed additional discovery, explaining how it contributes to the development of a comprehensive and accurate understanding of the facts and issues at hand. Highlight how this extra discovery will facilitate a fair and just resolution for all parties involved. 4. Description of Additional Discovery: Outline the specific details of the proposed additional discovery. This may include document requests, interrogatories, requests for admission, depositions, or any other relevant forms of discovery. Be thorough in explaining the necessity and potential impact of each requested item. 5. Collaboration and Agreement: If applicable, state that both parties are in agreement with the joint motion and emphasize the collaborative and cooperative nature of this request. Include any supporting documentation, such as a signed Joint Stipulation or agreement in writing between the parties. 6. Legal Basis and Compliance: Cite the relevant statutes, rules, or case law supporting the request for additional discovery. Show that the motion is in conformity with the rules and procedures of the Delaware court. 7. Proposed Schedule: Suggest a realistic and reasonable timeline for completing the additional discovery, including deadlines for the completion of specific tasks and the subsequent filing of necessary motions. 8. Conclusion: Express gratitude for the court's attention and consideration of this joint motion. Provide contact information should the court require any additional information or have any further inquiries regarding the motion. Thank you for your attention to this matter. We trust the court will recognize the merits of our joint motion and grant us leave to propound additional discovery. We remain at your disposal for any further clarification or documentation you may require. Sincerely, [Your Name] cc: [Opposing Counsel's Name] [Opposing Counsel's Address]

[Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] Clerk of the Court [Delaware Court Name] [Delaware Court Address] [City, State, ZIP] Re: Joint Motion for Leave to Propound Additional Discovery Case Name/Number: [Provide relevant case name and number] Dear Clerk, 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 aforementioned case. We kindly request the court's permission to expand the scope of discovery for the following reasons: 1. Background/Introduction: Provide a brief overview of the case, including the parties involved, the nature of the dispute, and any relevant background information. 2. Discovery Status: Briefly summarize the current discovery process, including the type and extent of discovery already propounded by both parties. 3. Purpose and Relevance of Additional Discovery: Clearly state the purpose and relevance of the proposed additional discovery, explaining how it contributes to the development of a comprehensive and accurate understanding of the facts and issues at hand. Highlight how this extra discovery will facilitate a fair and just resolution for all parties involved. 4. Description of Additional Discovery: Outline the specific details of the proposed additional discovery. This may include document requests, interrogatories, requests for admission, depositions, or any other relevant forms of discovery. Be thorough in explaining the necessity and potential impact of each requested item. 5. Collaboration and Agreement: If applicable, state that both parties are in agreement with the joint motion and emphasize the collaborative and cooperative nature of this request. Include any supporting documentation, such as a signed Joint Stipulation or agreement in writing between the parties. 6. Legal Basis and Compliance: Cite the relevant statutes, rules, or case law supporting the request for additional discovery. Show that the motion is in conformity with the rules and procedures of the Delaware court. 7. Proposed Schedule: Suggest a realistic and reasonable timeline for completing the additional discovery, including deadlines for the completion of specific tasks and the subsequent filing of necessary motions. 8. Conclusion: Express gratitude for the court's attention and consideration of this joint motion. Provide contact information should the court require any additional information or have any further inquiries regarding the motion. Thank you for your attention to this matter. We trust the court will recognize the merits of our joint motion and grant us leave to propound additional discovery. We remain at your disposal for any further clarification or documentation you may require. Sincerely, [Your Name] cc: [Opposing Counsel's Name] [Opposing Counsel's Address]

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Delaware Sample Letter to Clerk for filing Joint Motion for Leave to Propound Additional Discovery