This form is a sample letter in Word format covering the subject matter of the title of the form.
***Keywords: Kansas, Sample Letter, Joint Motion, Entry, Second Amended Scheduling Order*** [Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] [Recipient's Name] [Recipient's Address] [City, State, ZIP] Subject: Joint Motion of Entry of Second Amended Scheduling Order Case Number: [Case Number] Dear [Recipient's Name], I hope this letter finds you well. I am writing to submit a Joint Motion of Entry of Second Amended Scheduling Order on behalf of all parties involved in the above-mentioned case. As per the stipulations agreed upon by both parties, we respectfully request the court's approval for the following amendments to the original scheduling order: 1. Deadline Extension: We propose an extension of the existing deadlines outlined in the initial scheduling order. This is necessary due to unforeseen circumstances that have affected the ability of both parties to meet the previously set timelines. The extension will provide adequate time for all parties to prepare their cases thoroughly and ensure a fair and equitable resolution. 2. Discovery Phase Modification: In light of new evidence obtained during the discovery phase, we request permission to modify the timeline for completing the discovery process. This will allow both parties to conduct additional investigations, gather necessary evidence, and submit any relevant documentation. 3. Expert Witness Disclosure: We propose an alteration to the deadlines for expert witness disclosure, including both the identification of experts and the exchange of expert reports. This modification will enable all parties to include the most up-to-date expert opinions and testimony, promoting a comprehensive and informed legal process. 4. Trial Preparation Extension: Considering the time required for a comprehensive review of all evidence, we seek an extension to the trial preparation period. This will ensure that both parties have ample time to prepare witness statements, trial exhibits, and any other necessary components for a smooth and efficient trial. We believe that the proposed amendments to the original scheduling order are reasonable, given the circumstances and the paramount goal of achieving justice and fairness for all parties involved. By granting this motion, the court will contribute to a more effective and efficient legal process, reducing the chances of any procedural deficiencies that may impact the case's outcome. Additionally, both parties have cordially agreed to the proposed amendments, signifying our commitment to expediting the case while maintaining a high standard of legal practice. Enclosed with this letter, you will find a copy of the Joint Motion of Entry of Second Amended Scheduling Order, along with supporting documentation and signatures from all involved parties. We kindly request that you file the amended order with the court and provide us with a copy for our records. Thank you for your attention to this matter. We sincerely hope that the court will consider our joint motion favorably. Should you require any additional information or clarification, please do not hesitate to contact me at [Your Phone Number] or [Your Email Address]. We appreciate your understanding and cooperation and look forward to a swift resolution of this case. Yours sincerely, [Your Name] [Your Law Firm, if applicable] [Your Law Firm's Address] [City, State, ZIP]
***Keywords: Kansas, Sample Letter, Joint Motion, Entry, Second Amended Scheduling Order*** [Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] [Recipient's Name] [Recipient's Address] [City, State, ZIP] Subject: Joint Motion of Entry of Second Amended Scheduling Order Case Number: [Case Number] Dear [Recipient's Name], I hope this letter finds you well. I am writing to submit a Joint Motion of Entry of Second Amended Scheduling Order on behalf of all parties involved in the above-mentioned case. As per the stipulations agreed upon by both parties, we respectfully request the court's approval for the following amendments to the original scheduling order: 1. Deadline Extension: We propose an extension of the existing deadlines outlined in the initial scheduling order. This is necessary due to unforeseen circumstances that have affected the ability of both parties to meet the previously set timelines. The extension will provide adequate time for all parties to prepare their cases thoroughly and ensure a fair and equitable resolution. 2. Discovery Phase Modification: In light of new evidence obtained during the discovery phase, we request permission to modify the timeline for completing the discovery process. This will allow both parties to conduct additional investigations, gather necessary evidence, and submit any relevant documentation. 3. Expert Witness Disclosure: We propose an alteration to the deadlines for expert witness disclosure, including both the identification of experts and the exchange of expert reports. This modification will enable all parties to include the most up-to-date expert opinions and testimony, promoting a comprehensive and informed legal process. 4. Trial Preparation Extension: Considering the time required for a comprehensive review of all evidence, we seek an extension to the trial preparation period. This will ensure that both parties have ample time to prepare witness statements, trial exhibits, and any other necessary components for a smooth and efficient trial. We believe that the proposed amendments to the original scheduling order are reasonable, given the circumstances and the paramount goal of achieving justice and fairness for all parties involved. By granting this motion, the court will contribute to a more effective and efficient legal process, reducing the chances of any procedural deficiencies that may impact the case's outcome. Additionally, both parties have cordially agreed to the proposed amendments, signifying our commitment to expediting the case while maintaining a high standard of legal practice. Enclosed with this letter, you will find a copy of the Joint Motion of Entry of Second Amended Scheduling Order, along with supporting documentation and signatures from all involved parties. We kindly request that you file the amended order with the court and provide us with a copy for our records. Thank you for your attention to this matter. We sincerely hope that the court will consider our joint motion favorably. Should you require any additional information or clarification, please do not hesitate to contact me at [Your Phone Number] or [Your Email Address]. We appreciate your understanding and cooperation and look forward to a swift resolution of this case. Yours sincerely, [Your Name] [Your Law Firm, if applicable] [Your Law Firm's Address] [City, State, ZIP]