[Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] Clerk of the Court [Name of the Court] [Address] [City, State, ZIP] Re: Joint Motion for Leave to Propound Additional Discovery Case Number: [Case Number] Plaintiff: [Name of Plaintiff] Defendant: [Name of Defendant] Dear Clerk of the Court, I hope this letter finds you well. I am writing to request the filing of a Joint Motion for Leave to Propound Additional Discovery in the above-mentioned case. Please find enclosed the necessary documents for your review and further action. We, the undersigned parties in this case, jointly request the court's permission to engage in additional discovery. This motion is being filed pursuant to the Massachusetts Rules of Civil Procedure, Rule X, which allows parties to file a joint motion seeking leave to engage in additional discovery after the initial discovery phase has been completed. The purpose of this joint motion is to expand the scope of discovery in order to gather additional information that is relevant to the issues at hand in this case. We believe that this additional discovery is crucial to fully and fairly present our respective positions before the court. The requested additional discovery will assist in clarifying factual matters, resolving disputes, and ensuring the just resolution of this case. In support of our joint motion, we have attached the following documents for your reference: 1. Joint Motion for Leave to Propound Additional Discovery — This document outlines our request for additional discovery and the relevant legal grounds for this motion. 2. Proposed Additional Discovery Requests — We have prepared a set of proposed additional discovery requests that outline the specific information we seek to obtain through this process. These requests are carefully crafted to be proportional, reasonable, and necessary for a thorough examination of the relevant facts. 3. Certification of Counsel — This document certifies that both parties have engaged in good-faith efforts to resolve any discoverable disputes before filing this joint motion. We kindly request that you review the enclosed documents and file them with the court. We would appreciate it if you could provide us with a filed-stamped copy of the joint motion for our records. Furthermore, we would be grateful if you could schedule a hearing on this motion at the earliest convenience of the court. We understand that the court's schedule may impact the hearing date, but we reiterate the importance of expeditious consideration due to the significance of the additional discovery sought. If there are any additional fees or requirements associated with filing this motion, please inform us in writing, and we will promptly fulfill them. We are fully committed to complying with all necessary procedures to ensure a smooth and efficient resolution of this matter. Thank you for your attention to this matter. We trust that you will give our joint motion the necessary consideration it deserves. Should you require any further information or clarification, please do not hesitate to contact me at the above-mentioned contact details. Yours sincerely, [Your Name and Signature] [Your Title/Position, if applicable]
[Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] Clerk of the Court [Name of the Court] [Address] [City, State, ZIP] Re: Joint Motion for Leave to Propound Additional Discovery Case Number: [Case Number] Plaintiff: [Name of Plaintiff] Defendant: [Name of Defendant] Dear Clerk of the Court, I hope this letter finds you well. I am writing to request the filing of a Joint Motion for Leave to Propound Additional Discovery in the above-mentioned case. Please find enclosed the necessary documents for your review and further action. We, the undersigned parties in this case, jointly request the court's permission to engage in additional discovery. This motion is being filed pursuant to the Massachusetts Rules of Civil Procedure, Rule X, which allows parties to file a joint motion seeking leave to engage in additional discovery after the initial discovery phase has been completed. The purpose of this joint motion is to expand the scope of discovery in order to gather additional information that is relevant to the issues at hand in this case. We believe that this additional discovery is crucial to fully and fairly present our respective positions before the court. The requested additional discovery will assist in clarifying factual matters, resolving disputes, and ensuring the just resolution of this case. In support of our joint motion, we have attached the following documents for your reference: 1. Joint Motion for Leave to Propound Additional Discovery — This document outlines our request for additional discovery and the relevant legal grounds for this motion. 2. Proposed Additional Discovery Requests — We have prepared a set of proposed additional discovery requests that outline the specific information we seek to obtain through this process. These requests are carefully crafted to be proportional, reasonable, and necessary for a thorough examination of the relevant facts. 3. Certification of Counsel — This document certifies that both parties have engaged in good-faith efforts to resolve any discoverable disputes before filing this joint motion. We kindly request that you review the enclosed documents and file them with the court. We would appreciate it if you could provide us with a filed-stamped copy of the joint motion for our records. Furthermore, we would be grateful if you could schedule a hearing on this motion at the earliest convenience of the court. We understand that the court's schedule may impact the hearing date, but we reiterate the importance of expeditious consideration due to the significance of the additional discovery sought. If there are any additional fees or requirements associated with filing this motion, please inform us in writing, and we will promptly fulfill them. We are fully committed to complying with all necessary procedures to ensure a smooth and efficient resolution of this matter. Thank you for your attention to this matter. We trust that you will give our joint motion the necessary consideration it deserves. Should you require any further information or clarification, please do not hesitate to contact me at the above-mentioned contact details. Yours sincerely, [Your Name and Signature] [Your Title/Position, if applicable]
