Nebraska Sample Letter for Joint Motion of Entry of Second Amended Scheduling Order

• Category: Letters - Legal - Motions
• State: Multi-State
• Control #: US-0865LTR
• Format: Word; Rich Text

Description

This form is a sample letter in Word format covering the subject matter of the title of the form. Nebraska Sample Letter for Joint Motion of Entry of Second Amended Scheduling Order: [Your Name] [Your Address] [City, State, ZIP Code] [Email Address] [Phone Number] [Date] [Recipient's Name] [Recipient's Position] [Court's Name] [Court's Address] [City, State, ZIP Code] Subject: Joint Motion of Entry of Second Amended Scheduling Order Dear [Recipient's Name], I hope this letter finds you well. I, [Your Name], representing [Your Client's Name], respectfully submit this joint motion on behalf of all parties involved in the case [Case Name], requesting the entry of a Second Amended Scheduling Order in accordance with the Nebraska Rules of Civil Procedure. This joint motion is being filed collaboratively by all parties to address the need for modifications to the existing scheduling order due to unforeseen circumstances or unavoidable changes in the litigation process. The proposed modifications aim to ensure that the case proceedings run smoothly, efficiently, and fairly, considering the best interests of all parties involved. We hereby provide a detailed description of the proposed amendments to the existing scheduling order: 1. Amendment Reason: [Provide a clear and concise explanation of why the amendment is necessary. Elaborate on any changes in the parties' responsibilities, disclosure requirements, or any other relevant factors]. 2. Amend Deadline for Discovery: [Specify the new deadline for completion of discovery, including the identification of witnesses, exchange of expert witness reports, and completion of depositions]. 3. Adjust Deadlines for Dispositive Motions: [Specify any changes to the deadlines for filing dispositive motions, responses, and replies, taking into account the time required for parties to prepare their arguments and for the court to review and rule upon them]. 4. Modify Pre-Trial Conference Date: [Propose a new date for the pre-trial conference, allowing sufficient time for parties to finalize exhibits, witness lists, and any other necessary preparations]. 5. Revise Trial Date: [Suggest a new trial date that considers the additional time required for completion of the amended schedule, avoiding any conflicts with parties' availability or court's calendar]. Attached to this motion, please find a copy of the proposed Second Amended Scheduling Order for your review and consideration. We have made every effort to draft these amendments with precision, ensuring compliance with the applicable Nebraska Rules of Civil Procedure. All parties have consented to this proposed joint motion, signifying their agreement to the requested modifications. We kindly request that the court grant this motion of entry of the Second Amended Scheduling Order at the earliest convenience. Thank you for your attention to this matter. Should you have any questions or require further information, please do not hesitate to contact me at [Your Phone Number] or via email at [Your Email Address]. Respectfully, [Your Name] [Your Law Firm's Name (if applicable)] [Your Law Firm's Address (if applicable)] [City, State, ZIP Code]

Nebraska Sample Letter for Joint Motion of Entry of Second Amended Scheduling Order: [Your Name] [Your Address] [City, State, ZIP Code] [Email Address] [Phone Number] [Date] [Recipient's Name] [Recipient's Position] [Court's Name] [Court's Address] [City, State, ZIP Code] Subject: Joint Motion of Entry of Second Amended Scheduling Order Dear [Recipient's Name], I hope this letter finds you well. I, [Your Name], representing [Your Client's Name], respectfully submit this joint motion on behalf of all parties involved in the case [Case Name], requesting the entry of a Second Amended Scheduling Order in accordance with the Nebraska Rules of Civil Procedure. This joint motion is being filed collaboratively by all parties to address the need for modifications to the existing scheduling order due to unforeseen circumstances or unavoidable changes in the litigation process. The proposed modifications aim to ensure that the case proceedings run smoothly, efficiently, and fairly, considering the best interests of all parties involved. We hereby provide a detailed description of the proposed amendments to the existing scheduling order: 1. Amendment Reason: [Provide a clear and concise explanation of why the amendment is necessary. Elaborate on any changes in the parties' responsibilities, disclosure requirements, or any other relevant factors]. 2. Amend Deadline for Discovery: [Specify the new deadline for completion of discovery, including the identification of witnesses, exchange of expert witness reports, and completion of depositions]. 3. Adjust Deadlines for Dispositive Motions: [Specify any changes to the deadlines for filing dispositive motions, responses, and replies, taking into account the time required for parties to prepare their arguments and for the court to review and rule upon them]. 4. Modify Pre-Trial Conference Date: [Propose a new date for the pre-trial conference, allowing sufficient time for parties to finalize exhibits, witness lists, and any other necessary preparations]. 5. Revise Trial Date: [Suggest a new trial date that considers the additional time required for completion of the amended schedule, avoiding any conflicts with parties' availability or court's calendar]. Attached to this motion, please find a copy of the proposed Second Amended Scheduling Order for your review and consideration. We have made every effort to draft these amendments with precision, ensuring compliance with the applicable Nebraska Rules of Civil Procedure. All parties have consented to this proposed joint motion, signifying their agreement to the requested modifications. We kindly request that the court grant this motion of entry of the Second Amended Scheduling Order at the earliest convenience. Thank you for your attention to this matter. Should you have any questions or require further information, please do not hesitate to contact me at [Your Phone Number] or via email at [Your Email Address]. Respectfully, [Your Name] [Your Law Firm's Name (if applicable)] [Your Law Firm's Address (if applicable)] [City, State, ZIP Code]