New Mexico Sample Letter to Clerk for filing Joint Motion for Leave to Propound Additional Discovery

• Category: Letters - Legal - Motions
• State: Multi-State
• Control #: US-0863LTR
• 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] [New Mexico District Court Clerk's Office] [Address] [City, State, ZIP] Subject: Joint Motion for Leave to Propound Additional Discovery Dear Clerk of the Court, I hope this letter finds you well. I am writing to file a Joint Motion for Leave to Propound Additional Discovery in relation to the ongoing case [Case Name and Number] in the [New Mexico District Court]. As the plaintiff/defendant in this case, I, along with the opposing party [Include opposing party's name and contact details here], respectfully request the Court's permission to propound additional discovery beyond the existing discovery limits set forth in the [Provide details of the existing case scheduling order or any protective orders, if applicable]. In order to ensure a fair and just resolution to this matter, it is crucial to gather additional information that will contribute to a comprehensive understanding of the facts, evidence, and issues involved. We believe that the proposed additional discovery is necessary to obtain relevant documents, conduct depositions, and gather other necessary evidence to bolster our respective positions. The proposed additional discovery will enable us to clarify and narrow down intricate legal aspects, resolve any ambiguities, and ascertain the full extent of the facts surrounding this case. The information sought will aid in promoting informed and efficient proceedings, ensuring that justice is served for all parties involved. We hereby submit the following details and accompanying documents for your records: 1. Proposed Additional Discovery Requests: Enclosed, please find a comprehensive list of the specific discovery requests we wish to propound. These requests adhere to the guidelines set forth in the Federal Rules of Civil Procedure, Section XX [Insert applicable rule number], and the local court rules. 2. Proposed Schedule: We propose the following schedule to ensure timely completion of the additional discovery process: a. Deadline for the opposing party's response to the motion: [Specify a date within the court's specified timeline for responses] b. Deadline for the court's ruling on the motion: [Specify a date within the court's specified timeline for hearings and rulings] We kindly request that the court calendar a hearing to address this motion in accordance with the court's guidelines. We are confident that the proposed additional discovery will contribute significantly to the efficient and just resolution of this case. We assure the Court that all parties involved will actively participate in complying with any orders related to the additional discovery and will diligently work to prevent any unnecessary delay or inconvenience. Thank you for your attention to this matter. Please find enclosed the necessary filing fee, along with a copy of this letter, proposed additional discovery requests, and any supporting documentation. Should you require any further information or documentation, please do not hesitate to contact me at the address and contact details provided above. We appreciate your time and consideration. Yours sincerely, [Your Name] [Your Case Role: Plaintiff/Defendant] [Your Attorney, if applicable] [Your Attorney's Contact Details, if applicable]

[Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] [New Mexico District Court Clerk's Office] [Address] [City, State, ZIP] Subject: Joint Motion for Leave to Propound Additional Discovery Dear Clerk of the Court, I hope this letter finds you well. I am writing to file a Joint Motion for Leave to Propound Additional Discovery in relation to the ongoing case [Case Name and Number] in the [New Mexico District Court]. As the plaintiff/defendant in this case, I, along with the opposing party [Include opposing party's name and contact details here], respectfully request the Court's permission to propound additional discovery beyond the existing discovery limits set forth in the [Provide details of the existing case scheduling order or any protective orders, if applicable]. In order to ensure a fair and just resolution to this matter, it is crucial to gather additional information that will contribute to a comprehensive understanding of the facts, evidence, and issues involved. We believe that the proposed additional discovery is necessary to obtain relevant documents, conduct depositions, and gather other necessary evidence to bolster our respective positions. The proposed additional discovery will enable us to clarify and narrow down intricate legal aspects, resolve any ambiguities, and ascertain the full extent of the facts surrounding this case. The information sought will aid in promoting informed and efficient proceedings, ensuring that justice is served for all parties involved. We hereby submit the following details and accompanying documents for your records: 1. Proposed Additional Discovery Requests: Enclosed, please find a comprehensive list of the specific discovery requests we wish to propound. These requests adhere to the guidelines set forth in the Federal Rules of Civil Procedure, Section XX [Insert applicable rule number], and the local court rules. 2. Proposed Schedule: We propose the following schedule to ensure timely completion of the additional discovery process: a. Deadline for the opposing party's response to the motion: [Specify a date within the court's specified timeline for responses] b. Deadline for the court's ruling on the motion: [Specify a date within the court's specified timeline for hearings and rulings] We kindly request that the court calendar a hearing to address this motion in accordance with the court's guidelines. We are confident that the proposed additional discovery will contribute significantly to the efficient and just resolution of this case. We assure the Court that all parties involved will actively participate in complying with any orders related to the additional discovery and will diligently work to prevent any unnecessary delay or inconvenience. Thank you for your attention to this matter. Please find enclosed the necessary filing fee, along with a copy of this letter, proposed additional discovery requests, and any supporting documentation. Should you require any further information or documentation, please do not hesitate to contact me at the address and contact details provided above. We appreciate your time and consideration. Yours sincerely, [Your Name] [Your Case Role: Plaintiff/Defendant] [Your Attorney, if applicable] [Your Attorney's Contact Details, if applicable]