Dear [Clerk's Name], RE: Filing of Joint Motion for Leave to Propound Additional Discovery I hope this letter finds you in good health. I am writing to submit a joint motion on behalf of the parties involved in the aforementioned case, seeking leave to propound additional discovery in Kansas. The purpose of this correspondence is to provide the necessary details and request your assistance in filing this motion. 1. Background: (State a brief summary of the case and its current stage, explaining the need for additional discovery.) 2. Parties Involved: (Provide the names and relevant information of the parties involved in the case, including their respective attorneys.) 3. Motion for Leave: (Explain the purpose of the motion, emphasizing the need for additional discovery and its significance in furthering the interests of justice.) 4. Discovery Requests: (Provide a clear and concise list of the specific discovery requests planned by both parties. These requests should be relevant, narrowly tailored, and explain why they are necessary for the case.) 5. Legal Basis: (Briefly mention the statutory or case law support that justifies the request for additional discovery.) 6. Agreement of Both Parties: (Confirm that the motion is being submitted jointly by all parties involved, indicating consent and cooperation from both sides.) 7. Proposed Timeline: (Suggest a reasonable timeline within which the court can rule on the motion and allow for further discovery.) 8. Enclosed Documents: (List any documents attached to the letter that support the motion, such as proposed discovery requests.) 9. Conclusion: (State appreciation for the court's consideration and express confidence in the importance of allowing further discovery for the fair and just resolution of the case.) Thank you for your attention to this matter. I have enclosed two copies of the joint motion for your review and filing. If there are any additional forms or documents required, kindly inform us, and we will promptly provide them. Should you have any questions or require further information, please do not hesitate to contact either party's attorney listed below. We appreciate your assistance in expediting this process, and we look forward to your positive response. Yours sincerely, [Your Name] [Your Law Firm/Address] [Phone Number] [Email Address] Copies to: [Opposing Counsel's Name] [Opposing Counsel's Law Firm/Address] [Phone Number] [Email Address]