[Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] [Name of Clerk] [Name of Court] [Address] [City, State, ZIP] Re: Joint Motion for Leave to Propound Additional Discovery Dear [Name of Clerk], I hope this letter finds you well. I am writing to file a Joint Motion for Leave to Propound Additional Discovery in the above-mentioned case and respectfully request that you consider our motion as per the following details. Case Information: — Caption: [Plaintiff(s) vs. Defendant(s)] — Case Number: [Case Number— - Court: [Name of Court] — Judge: [Judge's Name— - Filing Date: [Filing Date] We, the undersigned parties, [Plaintiff's Name(s)] and [Defendant's Name(s)], hereby jointly request the court's permission to propound additional discovery in the form of [specific type of discovery], pertaining to the above-mentioned case. Our grounds for seeking this additional discovery are as follows: 1. Relevance: The requested discovery will provide crucial information to both parties by shedding light on [specific aspect or issue] that is central to the case. The information sought is expected to further clarify the facts and circumstances of the events in question. 2. Materiality: The information subject to our additional discovery request is material and relevant to the determination of liability, damages, or any other issue being litigated. The discovery is necessary for a fair and just resolution of the case. 3. Proportionality: Both parties have exercised due diligence in conducting prior discovery efforts, diligently exhausting all reasonable avenues for gathering relevant information. However, due to the complexity and evolving nature of the case, the discovery thus far cannot sufficiently address specific elements pivotal to the fair adjudication of the matter. To support our motion, we have attached the following documents: 1. Joint Motion for Leave to Propound Additional Discovery 2. Proposed Additional Discovery Requests 3. Certificate of Conference between Parties 4. Proposed Order Granting Joint Motion for Leave to Propound Additional Discovery We kindly request that you file these documents with the court and provide us with confirmation of receipt. In compliance with the applicable court rules, we have served copies of this joint motion, along with the attached documents, to all relevant parties in accordance with the proper service rules and requirements. Based on the above, we respectfully ask the court to grant our Joint Motion for Leave to Propound Additional Discovery, and we hereby request a prompt hearing on this matter. Thank you for your attention to this request. Should you require any additional information or have any further instructions, please do not hesitate to contact us. Sincerely, [Your Name] [Your Signature] CC: [List of Parties to be Cc'd]