North Carolina Sample Letter conveying Joint Motion for Leave to Propound Additional Discovery

• Category: Letters - Legal - Discovery
• State: Multi-State
• Control #: US-0092LTR
• Format: Word; Rich Text

Description

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] [Email Address] [Phone Number] [Date] [Recipient's Name] [Recipient's Address] [City, State, ZIP] Subject: Joint Motion for Leave to Propound Additional Discovery 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 on behalf of [Party A] and [Party B] in the [Case Name], currently pending in the [Court Name]. In accordance with the North Carolina Rules of Civil Procedure, specifically Rule [Rule Number], we seek the Court's permission to serve additional discovery requests upon the opposing party. These requests are crucial for adequately preparing and presenting our case. We believe that granting this motion will facilitate a fair and just resolution of the matter. [Party A] and [Party B] collectively assert that the following grounds warrant the requested leave: 1. Complexity of the issues: The issues involved in the case are highly complex, and due to their intricacy, additional discovery is necessary to uncover essential facts and evidence required for a comprehensive understanding of the matter. 2. New evidence: We have recently obtained new evidence that significantly impacts the case. This evidence was discovered after the initial discovery period, and therefore, necessitates the request for additional discovery. 3. Identifying additional witnesses: Due to the evolution of the case and the discovery of new evidence, it has become imperative to identify and depose additional witnesses who may have vital information pertaining to the case. Granting this motion will allow us to thoroughly examine these witnesses and present their testimony at trial, ensuring a more accurate determination of the truth. 4. Clarification of existing evidence: By propounding additional discovery, it will be possible to obtain clarifications on existing evidence and responses to previous interrogatories or requests for production of documents. Such clarification is essential to ensure fairness and eliminate ambiguities presented during the discovery process. 5. Substantial interest of the parties: The outcome of this case carries significant consequences for both [Party A] and [Party B]. Additional discovery is necessary to ensure that justice is served and that our clients' rights and interests are adequately protected. Based on the aforementioned grounds, we kindly request the Court's permission to propound additional discovery on the opposing party. Included with this letter is a proposed Joint Motion for Leave to Propound Additional Discovery, along with any necessary supporting documents as required by the Court. We respectfully ask for a timely response to this motion, as it directly affects the efficient progress of the case. If necessary, we are prepared to appear for a hearing to address any questions or concerns the Court may have regarding this request. Thank you for your attention to this matter. We look forward to your favorable response. Sincerely, [Your Name] [Your Law Firm Name, if applicable] [Your Bar Number, if applicable]

[Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] [Recipient's Name] [Recipient's Address] [City, State, ZIP] Subject: Joint Motion for Leave to Propound Additional Discovery 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 on behalf of [Party A] and [Party B] in the [Case Name], currently pending in the [Court Name]. In accordance with the North Carolina Rules of Civil Procedure, specifically Rule [Rule Number], we seek the Court's permission to serve additional discovery requests upon the opposing party. These requests are crucial for adequately preparing and presenting our case. We believe that granting this motion will facilitate a fair and just resolution of the matter. [Party A] and [Party B] collectively assert that the following grounds warrant the requested leave: 1. Complexity of the issues: The issues involved in the case are highly complex, and due to their intricacy, additional discovery is necessary to uncover essential facts and evidence required for a comprehensive understanding of the matter. 2. New evidence: We have recently obtained new evidence that significantly impacts the case. This evidence was discovered after the initial discovery period, and therefore, necessitates the request for additional discovery. 3. Identifying additional witnesses: Due to the evolution of the case and the discovery of new evidence, it has become imperative to identify and depose additional witnesses who may have vital information pertaining to the case. Granting this motion will allow us to thoroughly examine these witnesses and present their testimony at trial, ensuring a more accurate determination of the truth. 4. Clarification of existing evidence: By propounding additional discovery, it will be possible to obtain clarifications on existing evidence and responses to previous interrogatories or requests for production of documents. Such clarification is essential to ensure fairness and eliminate ambiguities presented during the discovery process. 5. Substantial interest of the parties: The outcome of this case carries significant consequences for both [Party A] and [Party B]. Additional discovery is necessary to ensure that justice is served and that our clients' rights and interests are adequately protected. Based on the aforementioned grounds, we kindly request the Court's permission to propound additional discovery on the opposing party. Included with this letter is a proposed Joint Motion for Leave to Propound Additional Discovery, along with any necessary supporting documents as required by the Court. We respectfully ask for a timely response to this motion, as it directly affects the efficient progress of the case. If necessary, we are prepared to appear for a hearing to address any questions or concerns the Court may have regarding this request. Thank you for your attention to this matter. We look forward to your favorable response. Sincerely, [Your Name] [Your Law Firm Name, if applicable] [Your Bar Number, if applicable]