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 Position] [Company/Organization Name] [Address] [City, State, ZIP] Subject: Joint Motion for Leave to Propound Additional Discovery — [Case Name/Number] Dear [Recipient's Name], I hope this letter finds you in good health and high spirits. I am writing to you as a party to the ongoing litigation in the [Case Name/Number] matter. Please accept this joint motion along with [Party's Name] seeking leave to propound additional discovery in accordance with the applicable rules and procedures in Florida. As you are aware, discovery plays a crucial role in the fair administration of justice. It allows parties to obtain relevant information necessary to prepare their cases, evaluate evidence, and reach a just resolution. In light of recent developments and upon consultation with my client, we have identified the need for additional discovery in order to adequately present our case and protect our client's interests. We propose to propound the following additional discovery requests: 1. Interrogatories: We seek the opportunity to serve [Party's Name]'s Interrogatories upon all parties involved in this litigation. These interrogatories will specifically focus on [insert specific topics, relevant to the case]. 2. Requests for Production of Documents: We request permission to serve [Party's Name]'s requests for the production of relevant documents from all parties. These documents will include, but are not limited to, [list examples of specific documents or categories of documents that are relevant to the case]. 3. Requests for Admission: We believe it's necessary to serve [Party's Name]'s requests for admission upon all parties. These requests, when answered under oath, will establish certain facts, eliminate issues in dispute, and narrow down the scope of litigation. It is important to note that these additional discovery requests are intended to facilitate a thorough and fair presentation of evidence. Our aim is to expedite the resolution of this case while ensuring that all parties have access to the necessary information and documents. In accordance with the procedures set forth in Florida Rule of Civil Procedure [insert applicable rule number], we kindly request that the Court grant us leave to propound the aforementioned additional discovery requests. We have taken into consideration the time limits prescribed by the rules and assure the Court that ample time will be provided for the parties to respond. Attached to this letter, you will find a copy of the Joint Motion for Leave to Propound Additional Discovery, prepared in compliance with the applicable rules of the Florida courts. We kindly request that you review the joint motion and, if in agreement, express your consent by promptly signing and returning a fully executed copy to our office. Upon receipt of your executed joint motion, we will promptly file it with the Court, serving a copy on all parties involved in this litigation. We trust that the Court will recognize the importance of this additional discovery and grant our motion in order to foster a fair and just resolution of the case. Thank you for your attention to this matter. We appreciate your cooperation and look forward to your prompt response. Yours sincerely, [Your Name]
[Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] [Recipient's Name] [Recipient's Position] [Company/Organization Name] [Address] [City, State, ZIP] Subject: Joint Motion for Leave to Propound Additional Discovery — [Case Name/Number] Dear [Recipient's Name], I hope this letter finds you in good health and high spirits. I am writing to you as a party to the ongoing litigation in the [Case Name/Number] matter. Please accept this joint motion along with [Party's Name] seeking leave to propound additional discovery in accordance with the applicable rules and procedures in Florida. As you are aware, discovery plays a crucial role in the fair administration of justice. It allows parties to obtain relevant information necessary to prepare their cases, evaluate evidence, and reach a just resolution. In light of recent developments and upon consultation with my client, we have identified the need for additional discovery in order to adequately present our case and protect our client's interests. We propose to propound the following additional discovery requests: 1. Interrogatories: We seek the opportunity to serve [Party's Name]'s Interrogatories upon all parties involved in this litigation. These interrogatories will specifically focus on [insert specific topics, relevant to the case]. 2. Requests for Production of Documents: We request permission to serve [Party's Name]'s requests for the production of relevant documents from all parties. These documents will include, but are not limited to, [list examples of specific documents or categories of documents that are relevant to the case]. 3. Requests for Admission: We believe it's necessary to serve [Party's Name]'s requests for admission upon all parties. These requests, when answered under oath, will establish certain facts, eliminate issues in dispute, and narrow down the scope of litigation. It is important to note that these additional discovery requests are intended to facilitate a thorough and fair presentation of evidence. Our aim is to expedite the resolution of this case while ensuring that all parties have access to the necessary information and documents. In accordance with the procedures set forth in Florida Rule of Civil Procedure [insert applicable rule number], we kindly request that the Court grant us leave to propound the aforementioned additional discovery requests. We have taken into consideration the time limits prescribed by the rules and assure the Court that ample time will be provided for the parties to respond. Attached to this letter, you will find a copy of the Joint Motion for Leave to Propound Additional Discovery, prepared in compliance with the applicable rules of the Florida courts. We kindly request that you review the joint motion and, if in agreement, express your consent by promptly signing and returning a fully executed copy to our office. Upon receipt of your executed joint motion, we will promptly file it with the Court, serving a copy on all parties involved in this litigation. We trust that the Court will recognize the importance of this additional discovery and grant our motion in order to foster a fair and just resolution of the case. Thank you for your attention to this matter. We appreciate your cooperation and look forward to your prompt response. Yours sincerely, [Your Name]