New Mexico 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. Subject: Joint Motion of Entry of Second Amended Scheduling Order in the State of New Mexico [Your Name] [Address] [City, State, Zip Code] [Email Address] [Phone Number] [Date] [Judge's Name] [Judge's Designation] [New Mexico District Court] [Address] [City, State, Zip Code] RE: Joint Motion of Entry of Second Amended Scheduling Order Case No: [Case Number] Plaintiff: [Plaintiff's Name] Defendant: [Defendant's Name] Dear Honorable [Judge's Last Name], We, the undersigned parties to the above-mentioned case, submit this joint motion for the entry of a Second Amended Scheduling Order. In light of recent developments, we believe that modifying the existing scheduling order is necessary to ensure fair and efficient proceedings. 1. Background: Provide a concise background of the case, including any pertinent dates, events, or key legal issues. 2. Reason for Amendment: Explain the compelling reasons for seeking an amendment to the existing scheduling order. It may include new evidence, discovery disputes, changes in parties, unforeseen circumstances, or any other relevant factors. 3. Proposed Amended Schedule: Present a detailed outline of the proposed amendments, clearly stating the modifications for each phase of the litigation process, including: a. Discovery: Specify any alterations to the discovery timeline, crucial deadlines, and the inclusion of any new or additional discovery requests. b. Pretrial Proceedings: Provide any necessary adjustments to pretrial procedures, including the exchange of witness lists, expert reports, exhibit lists, stipulations, or dispositive motion deadlines. c. Trial: Mention any changes related to the trial date, proposed length, jury selection, pretrial conferences, and any other relevant trial preparations. d. Additional Matters: Address any ancillary matters that require consideration, such as alternative dispute resolution, settlement conferences, or any other relevant proceedings. 4. Agreement of Parties: State that all parties involved agree to these proposed amendments and have signed this joint motion. 5. Proposed Order: Attach a clean copy of the proposed Second Amended Scheduling Order for the court's convenience. 6. Conclusion: Express gratitude for the court's attention to this motion and request that it be granted on behalf of all parties involved to preserve the fairness and efficiency of the litigation process. We kindly request a prompt review and favorable consideration of this joint motion for the entry of the Second Amended Scheduling Order. Thank you for your attention to this matter. Respectfully submitted, [Plaintiff's Attorney Name] [Law Firm Name] [Address] [City, State, Zip Code] [Email Address] [Phone Number] [Defendant's Attorney Name] [Law Firm Name] [Address] [City, State, Zip Code] [Email Address] [Phone Number] [Signature lines for all parties] Types of New Mexico Sample Letters for Joint Motion of Entry of Amended Scheduling Order: 1. Sample Letter for Joint Motion of Entry of First Amended Scheduling Order 2. Sample Letter for Joint Motion of Entry of Third Amended Scheduling Order 3. Sample Letter for Joint Motion of Entry of Modified Scheduling Order Note: The specific amended scheduling order names will depend on the applicable case and the number of amendments submitted.

Subject: Joint Motion of Entry of Second Amended Scheduling Order in the State of New Mexico [Your Name] [Address] [City, State, Zip Code] [Email Address] [Phone Number] [Date] [Judge's Name] [Judge's Designation] [New Mexico District Court] [Address] [City, State, Zip Code] RE: Joint Motion of Entry of Second Amended Scheduling Order Case No: [Case Number] Plaintiff: [Plaintiff's Name] Defendant: [Defendant's Name] Dear Honorable [Judge's Last Name], We, the undersigned parties to the above-mentioned case, submit this joint motion for the entry of a Second Amended Scheduling Order. In light of recent developments, we believe that modifying the existing scheduling order is necessary to ensure fair and efficient proceedings. 1. Background: Provide a concise background of the case, including any pertinent dates, events, or key legal issues. 2. Reason for Amendment: Explain the compelling reasons for seeking an amendment to the existing scheduling order. It may include new evidence, discovery disputes, changes in parties, unforeseen circumstances, or any other relevant factors. 3. Proposed Amended Schedule: Present a detailed outline of the proposed amendments, clearly stating the modifications for each phase of the litigation process, including: a. Discovery: Specify any alterations to the discovery timeline, crucial deadlines, and the inclusion of any new or additional discovery requests. b. Pretrial Proceedings: Provide any necessary adjustments to pretrial procedures, including the exchange of witness lists, expert reports, exhibit lists, stipulations, or dispositive motion deadlines. c. Trial: Mention any changes related to the trial date, proposed length, jury selection, pretrial conferences, and any other relevant trial preparations. d. Additional Matters: Address any ancillary matters that require consideration, such as alternative dispute resolution, settlement conferences, or any other relevant proceedings. 4. Agreement of Parties: State that all parties involved agree to these proposed amendments and have signed this joint motion. 5. Proposed Order: Attach a clean copy of the proposed Second Amended Scheduling Order for the court's convenience. 6. Conclusion: Express gratitude for the court's attention to this motion and request that it be granted on behalf of all parties involved to preserve the fairness and efficiency of the litigation process. We kindly request a prompt review and favorable consideration of this joint motion for the entry of the Second Amended Scheduling Order. Thank you for your attention to this matter. Respectfully submitted, [Plaintiff's Attorney Name] [Law Firm Name] [Address] [City, State, Zip Code] [Email Address] [Phone Number] [Defendant's Attorney Name] [Law Firm Name] [Address] [City, State, Zip Code] [Email Address] [Phone Number] [Signature lines for all parties] Types of New Mexico Sample Letters for Joint Motion of Entry of Amended Scheduling Order: 1. Sample Letter for Joint Motion of Entry of First Amended Scheduling Order 2. Sample Letter for Joint Motion of Entry of Third Amended Scheduling Order 3. Sample Letter for Joint Motion of Entry of Modified Scheduling Order Note: The specific amended scheduling order names will depend on the applicable case and the number of amendments submitted.