Florida Sample Letter for Drafts of a Joint Motion for Additional Discovery and an Order Approving Same Date: [Date] [Sender's Name] [Sender's Address] [City, State, Zip Code] [Recipient's Name] [Recipient's Address] [City, State, Zip Code] Subject: Request for Joint Motion for Additional Discovery and Order Approving Same Dear [Recipient's Name], I hope this letter finds you well. I am writing on behalf of [Your Law Firm], representing [Your Client's Name], in the case of [Case Name], currently being heard in [Name of the Court]. As part of our ongoing efforts to ensure a fair and unbiased resolution of this matter, we are seeking additional discovery. The purpose of this joint motion is to formally request your cooperation in proceeding with additional discovery in accordance with the Florida Rules of Civil Procedure. Our objective is to gather essential information and evidence that will aid both parties in preparing for trial and ultimately reaching a just resolution. To initiate this process, we have attached two draft documents for your review and consideration. The first is a joint motion for additional discovery, which outlines the reasons for our request and the specific areas of discovery we wish to pursue. The second document is an order approving the joint motion for additional discovery, which we kindly ask your honor to enter if both parties reach an agreement. The joint motion for additional discovery addresses the following key points: 1. Background: A brief summary of the case and the need for added discovery. 2. Scope of Discovery: A detailed description of the specific areas in which we seek additional information and evidence. 3. Relevance and Necessity: A justification of why the requested discovery is essential to a fair resolution and how it will assist both parties in preparing for trial. 4. Proposed Timeline: A proposed schedule for completing the requested discovery, including deadlines for responses and productions. 5. Agreement to Share Costs: An agreement to share the reasonable costs associated with the requested additional discovery. We firmly believe that by engaging in additional discovery, we will be able to narrow the issues at hand, streamline the litigation process, and facilitate a more efficient and just trial. We hope to collaborate with you and your client in a cooperative and timely manner, allowing us to reach an agreement that benefits all parties involved. Please review the attached drafts and let us know if you have any suggested revisions or concerns. We appreciate your prompt attention to this matter and kindly request a response within [timeframe for response]. Should you find it necessary, we are open to scheduling a meeting to discuss this motion further and address any issues or questions you may have. Thank you for your cooperation and willingness to work together to enhance the discovery process. We look forward to a positive response and a productive collaboration throughout the remainder of this case. Sincerely, [Your Name] [Your Law Firm] [Contact Information]