[Your Name] [Your Address] [City, State, ZIP Code] [Email Address] [Phone Number] [Date] [Recipient's Name] [Recipient's Address] [City, State, ZIP Code] Re: Joint Motion for Leave to Propound Additional Discovery Dear [Recipient's Name], I hope this letter finds you well. We are writing to submit a joint motion for leave to propound additional discovery in relation to [state the case name and number]. While we understand that both parties have previously completed discovery, certain circumstances have arisen that necessitate an extension of the discovery phase. As you may be aware, the state of Minnesota provides litigants with various options to pursue fair and efficient legal proceedings. In our ongoing pursuit of justice, we kindly request your approval to explore supplementary discovery avenues to uncover crucial evidence that could significantly impact the outcome of the case. This motion seeks permission to expand the current discovery parameters and engage in further fact-finding. To help the court gain a comprehensive understanding of the reasons behind this request, we have attached supporting documents detailing the circumstances necessitating the additional discovery. These documents include: 1. Affidavit of [Affine's Name]: This affidavit outlines the specific grounds and justifications for our motion. It clarifies the relevance and materiality of the information sought and highlights the potential impact of this discovery to ensure a fair and impartial resolution. 2. Proposed Interrogatories and Requests for Production: As part of our joint motion, we have provided a detailed list of the interrogatories and requests for production that we seek to propound upon the opposing party. These interrogatories and requests for production are directly related to the issues at hand and aim to acquire new and vital evidence. 3. Proposed Protective Order: In recognition of the sensitive nature of some requested discovery materials, we have drafted a protective order to ensure the confidentiality and non-disclosure of any privileged information. We firmly believe that the requested additional discovery is essential to promoting a thorough and equitable resolution in this matter. By granting our joint motion, the court can enhance its ability to accurately weigh the evidence and facilitate a fair trial. We are committed to working cooperatively with all parties involved to ensure a seamless and timely discovery process. If you have any questions or require further information, please do not hesitate to contact me at [Your Phone Number] or [Your Email Address]. Thank you for your attention to this matter. We appreciate your consideration of our joint motion for leave to propound additional discovery as we strive for a just outcome. Sincerely, [Your Name] [Your Law Firm Name] [Law Firm Address] [City, State, ZIP Code]