Massachusetts Sample Letter conveying Joint Motion for Leave to Propound Additional Discovery

• Category: Letters - Legal - Discovery
• State: Multi-State
• Control #: US-0092LTR
• Format: Word; Rich Text

Description

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 Code] [Email Address] [Phone Number] [Date] [Opposing Party's Name] [Opposing Party's Address] [City, State, ZIP Code] Re: Joint Motion for Leave to Propound Additional Discovery — [Case Name and Number] Dear [Opposing Party's Name], I hope this letter finds you well. I am writing to you on behalf of my client, [Your Client's Name], and in accordance with the Massachusetts Rules of Civil Procedure, specifically Rule 26 and Rule 37(a)(3). As you may be aware, the discovery phase of our ongoing litigation is currently in progress. In light of recent developments and additional evidence that has surfaced, it is crucial for both parties to have an opportunity to further explore and gather necessary information through additional discovery. To that end, I am pleased to inform you that my client and I are jointly submitting this letter as a motion for leave to propound additional discovery upon your client, [Opposing Party's Client's Name]. We firmly believe that allowing such discovery will enable us to better understand the facts pertinent to this case and ensure an equitable resolution for all parties involved. The types of additional discovery that we seek to conduct may include, but are not limited to: 1. Interrogatories: Written questions that must be answered under oath by your client. These questions will aim to gather specific information and details regarding the claims and defenses presented in this case. 2. Requests for Production: A formal request seeking the production of documents, tangible items, or electronically stored information that is relevant to the issues at hand. 3. Requests for Admission: A request to have your client admit or deny certain facts or matters of opinion. This will help narrow down disputed issues and streamline the trial process. 4. Depositions: The opportunity to conduct sworn, out-of-court oral examinations of your client, witnesses, or other individuals with relevant knowledge or information concerning this case. We kindly request your cooperation in granting this joint motion for leave to propound additional discovery. By doing so, we can ensure a fair and comprehensive trial, promoting the interests of justice and facilitating a prompt resolution of this dispute. As per the Massachusetts Rules of Civil Procedure, we propose that upon receiving your consent to this joint motion, we shall promptly draft and submit the corresponding proposed order to the court for its consideration and approval. We believe that this collaborative approach will expedite the discovery process and enable us to present a stronger case during trial. Please review this motion carefully and provide us with your response within [enter number of days, usually 14 days] from the date of this letter. If you require any clarification or if you wish to discuss this matter further, please do not hesitate to contact me at [Your Phone Number] or via email at [Your Email Address]. Thank you for your attention to this motion, and we look forward to your prompt response. Sincerely, [Your Name] [Your Law Firm's Name] [Your Law Firm's Address] [City, State, ZIP Code]

[Your Name] [Your Address] [City, State, ZIP Code] [Email Address] [Phone Number] [Date] [Opposing Party's Name] [Opposing Party's Address] [City, State, ZIP Code] Re: Joint Motion for Leave to Propound Additional Discovery — [Case Name and Number] Dear [Opposing Party's Name], I hope this letter finds you well. I am writing to you on behalf of my client, [Your Client's Name], and in accordance with the Massachusetts Rules of Civil Procedure, specifically Rule 26 and Rule 37(a)(3). As you may be aware, the discovery phase of our ongoing litigation is currently in progress. In light of recent developments and additional evidence that has surfaced, it is crucial for both parties to have an opportunity to further explore and gather necessary information through additional discovery. To that end, I am pleased to inform you that my client and I are jointly submitting this letter as a motion for leave to propound additional discovery upon your client, [Opposing Party's Client's Name]. We firmly believe that allowing such discovery will enable us to better understand the facts pertinent to this case and ensure an equitable resolution for all parties involved. The types of additional discovery that we seek to conduct may include, but are not limited to: 1. Interrogatories: Written questions that must be answered under oath by your client. These questions will aim to gather specific information and details regarding the claims and defenses presented in this case. 2. Requests for Production: A formal request seeking the production of documents, tangible items, or electronically stored information that is relevant to the issues at hand. 3. Requests for Admission: A request to have your client admit or deny certain facts or matters of opinion. This will help narrow down disputed issues and streamline the trial process. 4. Depositions: The opportunity to conduct sworn, out-of-court oral examinations of your client, witnesses, or other individuals with relevant knowledge or information concerning this case. We kindly request your cooperation in granting this joint motion for leave to propound additional discovery. By doing so, we can ensure a fair and comprehensive trial, promoting the interests of justice and facilitating a prompt resolution of this dispute. As per the Massachusetts Rules of Civil Procedure, we propose that upon receiving your consent to this joint motion, we shall promptly draft and submit the corresponding proposed order to the court for its consideration and approval. We believe that this collaborative approach will expedite the discovery process and enable us to present a stronger case during trial. Please review this motion carefully and provide us with your response within [enter number of days, usually 14 days] from the date of this letter. If you require any clarification or if you wish to discuss this matter further, please do not hesitate to contact me at [Your Phone Number] or via email at [Your Email Address]. Thank you for your attention to this motion, and we look forward to your prompt response. Sincerely, [Your Name] [Your Law Firm's Name] [Your Law Firm's Address] [City, State, ZIP Code]