Delaware 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. Delaware Sample Letter for Joint Motion of Entry of Second Amended Scheduling Order [Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] [Judge's Name] [Judge's Designation] [Courthouse Name] [Court's Address] [City, State, ZIP] [Plaintiff's Name] [Plaintiff's Address] [City, State, ZIP] [Plaintiff's Attorney's Name] [Plaintiff's Attorney's Firm] [Attorney's Address] [City, State, ZIP] [Defendant's Name] [Defendant's Address] [City, State, ZIP] [Defendant's Attorney's Name] [Defendant's Attorney's Firm] [Attorney's Address] [City, State, ZIP] Re: Joint Motion of Entry of Second Amended Scheduling Order Dear Honorable [Judge's Last Name], We, the undersigned parties, hereby jointly move for the entry of a Second Amended Scheduling Order in the above-mentioned case, pursuant to the Delaware Rules of Civil Procedure. We respectfully request that the court grant this motion to accommodate the parties' needs and ensure an efficient and fair litigation process. The reasons for this motion are as follows: 1. Change in Circumstances: Since the entry of the previous Scheduling Order, new facts and developments have arisen that necessitate modification to the previously agreed-upon schedule. The parties believe that this amendment is crucial to ensure a thorough and just resolution of this case. 2. Discovery Issues: The parties have encountered unforeseen difficulties during the discovery process, such as the unavailability of essential witnesses and the need for additional time to gather critical evidence. These challenges have impeded progress and require an extension of certain deadlines to adequately address all relevant matters. 3. Settlement Negotiations: The parties have engaged in ongoing settlement discussions, and there is a genuine possibility of reaching a resolution outside of litigation. Granting the motion for the Second Amended Scheduling Order would allow the parties to continue exploring settlement options without jeopardizing the progress of the case. 4. Ensuring Efficiency: The parties believe that the proposed amended schedule, attached as Exhibit A, will not only accommodate the current circumstances but also improve the overall efficiency of the litigation process. The proposed changes to the scheduling order aim to streamline the proceedings, avoid unnecessary delays, and optimize the use of judicial resources. Based on the aforementioned reasons, we respectfully request that the Court approve and enter the proposed Second Amended Scheduling Order, as attached herewith as Exhibit A. The parties have diligently collaborated to develop a revised schedule that takes into account the needs and constraints of all involved. We believe that this joint motion serves the interests of justice and will facilitate the prompt resolution of this matter. Thank you for your attention to this matter, and we kindly ask for an early ruling on this motion. If the Court deems it necessary, we are available for a conference call or an in-person hearing to address any concerns or provide further clarification. Respectfully submitted, [Your Name] [Your Attorney's Name and Firm Name] [Plaintiff's Attorney's Name and Firm Name] [Defendant's Attorney's Name and Firm Name]

Delaware Sample Letter for Joint Motion of Entry of Second Amended Scheduling Order [Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] [Judge's Name] [Judge's Designation] [Courthouse Name] [Court's Address] [City, State, ZIP] [Plaintiff's Name] [Plaintiff's Address] [City, State, ZIP] [Plaintiff's Attorney's Name] [Plaintiff's Attorney's Firm] [Attorney's Address] [City, State, ZIP] [Defendant's Name] [Defendant's Address] [City, State, ZIP] [Defendant's Attorney's Name] [Defendant's Attorney's Firm] [Attorney's Address] [City, State, ZIP] Re: Joint Motion of Entry of Second Amended Scheduling Order Dear Honorable [Judge's Last Name], We, the undersigned parties, hereby jointly move for the entry of a Second Amended Scheduling Order in the above-mentioned case, pursuant to the Delaware Rules of Civil Procedure. We respectfully request that the court grant this motion to accommodate the parties' needs and ensure an efficient and fair litigation process. The reasons for this motion are as follows: 1. Change in Circumstances: Since the entry of the previous Scheduling Order, new facts and developments have arisen that necessitate modification to the previously agreed-upon schedule. The parties believe that this amendment is crucial to ensure a thorough and just resolution of this case. 2. Discovery Issues: The parties have encountered unforeseen difficulties during the discovery process, such as the unavailability of essential witnesses and the need for additional time to gather critical evidence. These challenges have impeded progress and require an extension of certain deadlines to adequately address all relevant matters. 3. Settlement Negotiations: The parties have engaged in ongoing settlement discussions, and there is a genuine possibility of reaching a resolution outside of litigation. Granting the motion for the Second Amended Scheduling Order would allow the parties to continue exploring settlement options without jeopardizing the progress of the case. 4. Ensuring Efficiency: The parties believe that the proposed amended schedule, attached as Exhibit A, will not only accommodate the current circumstances but also improve the overall efficiency of the litigation process. The proposed changes to the scheduling order aim to streamline the proceedings, avoid unnecessary delays, and optimize the use of judicial resources. Based on the aforementioned reasons, we respectfully request that the Court approve and enter the proposed Second Amended Scheduling Order, as attached herewith as Exhibit A. The parties have diligently collaborated to develop a revised schedule that takes into account the needs and constraints of all involved. We believe that this joint motion serves the interests of justice and will facilitate the prompt resolution of this matter. Thank you for your attention to this matter, and we kindly ask for an early ruling on this motion. If the Court deems it necessary, we are available for a conference call or an in-person hearing to address any concerns or provide further clarification. Respectfully submitted, [Your Name] [Your Attorney's Name and Firm Name] [Plaintiff's Attorney's Name and Firm Name] [Defendant's Attorney's Name and Firm Name]