[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 in [Case Name] Dear [Recipient’s Name], I hope this letter finds you well. I am writing to submit a Joint Motion for Leave to Propound Additional Discovery in the matter of [Case Name] pending before [Court Name]. Please find the enclosed motion, which we kindly ask you to review and bring to the attention of the presiding judge. Our joint motion seeks the permission of the court to conduct further discovery in this case. We firmly believe that the additional discovery will enable both parties to gather essential information crucial to presenting their respective positions and ensuring a fair and just resolution to this matter. The discovery requests we propose include, but are not limited to, the following: 1. Interrogatories: We request permission to submit additional interrogatories to the opposing party to elicit specific and pertinent information regarding [specific topic/issue]. 2. Requests for Production: We seek permission to serve further requests for production of documents and tangible things related to [specific topic/issue] in order to obtain necessary evidence for our case. 3. Requests for Admission: We request leave to submit additional requests for admission to the opposing party to clarify and authenticate facts or allegations relevant to the case. 4. Depositions: We propose seeking leave to conduct additional depositions of pertinent witnesses or parties involved in this case. These depositions will allow us to obtain crucial testimony and gather evidence to support our claims. We emphasize that the proposed additional discovery is essential to ensure a comprehensive and fair exploration of the facts and legal issues related to this case. It will undoubtedly aid both parties in preparing a strong and well-supported argument, which is crucial for the court to reach a just resolution. We believe that granting our joint motion for leave to propound additional discovery will promote the efficient and effective administration of justice through the acquisition of necessary evidence and the subsequent garnering of a clearer understanding of the facts at hand. We kindly request that you review the attached joint motion and bring it to the attention of the presiding judge. Furthermore, we remain open to discussing any possible modifications or limitations to the proposed additional discovery to accommodate the court's schedule and requirements. Please do not hesitate to contact me if you have any questions or require further information. Thank you for your attention to this matter. Yours sincerely, [Your Name]