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] [Recipient's Name] [Recipient's Designation] [Law Firm/Organization Name] [Address] [City, State, ZIP Code] Re: [Case Name and Docket Number] Dear [Recipient's Name], I hope this letter finds you well. I am writing on behalf of [Your Client's Name], the plaintiff/defendant in the aforementioned case, in regard to our joint motion for leave to propound additional discovery in the State of Missouri. As you are aware, under the Missouri Rules of Civil Procedure, parties are entitled to conduct discovery to facilitate a fair and just resolution of the case. In light of new information that has emerged during the course of this litigation, it has become necessary for both parties to seek permission from the court to further explore the facts surrounding this matter. We kindly request that you join us in filing a joint motion for leave to propound additional discovery, as the issues at hand call for a collaborative and comprehensive approach. By presenting a united front, we can demonstrate to the court our commitment to upholding the principles of fairness and transparency. The proposed additional discovery is crucial to uncovering the necessary evidence to substantiate our respective positions. We believe that by expanding the scope of discovery, we can effectively address any outstanding ambiguities and unearth pertinent facts that will substantially impact the outcome of this case. The additional discovery we propose includes, but is not limited to: 1. Interrogatories: We seek to submit a set of carefully tailored interrogatories to acquire specific information from the opposing party, intending to gain a deeper understanding of their contentions and to clarify any discrepancies that have arisen. 2. Requests for Production of Documents: Our joint motion seeks permission to request the opposing party to produce any relevant documents, records, or tangible items that are vital to the resolution of this case. 3. Depositions: We propose conducting additional depositions of key witnesses involved in this case to further explore the matters at hand and to capture any crucial testimonies that might have been overlooked. By working together in an open and cooperative manner, we believe that this additional discovery will be instrumental in ensuring a fair and just resolution for both parties involved. Moreover, engaging in a joint motion will not only save valuable time and resources but also streamline the discovery process by preventing duplication and unnecessary delays. In light of the significance and urgency of this matter, we request your prompt response to this joint motion. We kindly ask that you review the enclosed proposed joint motion and its exhibits, and if in agreement, affix your signature below the motion. Thank you for your attention to this matter. We look forward to your collaboration and to bringing about a swift and equitable resolution to the case. Should you have any questions or concerns, please do not hesitate to contact me at [Your Phone Number] or via email at [Your Email Address]. Sincerely, [Your Name] [Your Designation] [Law Firm/Organization Name] Enclosure: Proposed Joint Motion for Leave to Propound Additional Discovery
[Your Name] [Your Address] [City, State, ZIP Code] [Email Address] [Phone Number] [Date] [Recipient's Name] [Recipient's Designation] [Law Firm/Organization Name] [Address] [City, State, ZIP Code] Re: [Case Name and Docket Number] Dear [Recipient's Name], I hope this letter finds you well. I am writing on behalf of [Your Client's Name], the plaintiff/defendant in the aforementioned case, in regard to our joint motion for leave to propound additional discovery in the State of Missouri. As you are aware, under the Missouri Rules of Civil Procedure, parties are entitled to conduct discovery to facilitate a fair and just resolution of the case. In light of new information that has emerged during the course of this litigation, it has become necessary for both parties to seek permission from the court to further explore the facts surrounding this matter. We kindly request that you join us in filing a joint motion for leave to propound additional discovery, as the issues at hand call for a collaborative and comprehensive approach. By presenting a united front, we can demonstrate to the court our commitment to upholding the principles of fairness and transparency. The proposed additional discovery is crucial to uncovering the necessary evidence to substantiate our respective positions. We believe that by expanding the scope of discovery, we can effectively address any outstanding ambiguities and unearth pertinent facts that will substantially impact the outcome of this case. The additional discovery we propose includes, but is not limited to: 1. Interrogatories: We seek to submit a set of carefully tailored interrogatories to acquire specific information from the opposing party, intending to gain a deeper understanding of their contentions and to clarify any discrepancies that have arisen. 2. Requests for Production of Documents: Our joint motion seeks permission to request the opposing party to produce any relevant documents, records, or tangible items that are vital to the resolution of this case. 3. Depositions: We propose conducting additional depositions of key witnesses involved in this case to further explore the matters at hand and to capture any crucial testimonies that might have been overlooked. By working together in an open and cooperative manner, we believe that this additional discovery will be instrumental in ensuring a fair and just resolution for both parties involved. Moreover, engaging in a joint motion will not only save valuable time and resources but also streamline the discovery process by preventing duplication and unnecessary delays. In light of the significance and urgency of this matter, we request your prompt response to this joint motion. We kindly ask that you review the enclosed proposed joint motion and its exhibits, and if in agreement, affix your signature below the motion. Thank you for your attention to this matter. We look forward to your collaboration and to bringing about a swift and equitable resolution to the case. Should you have any questions or concerns, please do not hesitate to contact me at [Your Phone Number] or via email at [Your Email Address]. Sincerely, [Your Name] [Your Designation] [Law Firm/Organization Name] Enclosure: Proposed Joint Motion for Leave to Propound Additional Discovery