New York 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 Code] [Email Address] [Phone Number] [Date] [Recipient's Name] [Recipient's Address] [City, State, ZIP Code] Subject: Joint Motion for Leave to Propound Additional Discovery Dear [Recipient's Name], I hope this letter finds you well. I am writing to you on behalf of [Your Company/Organization] regarding the ongoing legal proceedings [Case Name/Number] pending in the [Court Name], pertaining to [Briefly describe the nature of the case]. As the discovery phase of the litigation proceeds, we have identified certain crucial pieces of information that require further investigation to ensure a fair and just resolution of the matter. Therefore, we hereby submit this joint motion for leave to propound additional discovery, as allowed under the legal framework prevailing in the state of New York. In accordance with the New York Civil Practice Law and Rules (CPR), specifically Rule 3101(f), which allows for additional discovery upon obtaining court permission, we respectfully request the Court's approval to undertake the following discovery actions: 1. Interrogatories: We propose to submit a set of written interrogatories to the opposing party to elicit specific information about [Describe the subject or area of information sought]. 2. Request for Production: We request permission to demand the opposing party to produce relevant documents, electronically stored information (ESI), records, or any other tangible evidence that pertains to [Specify the relevant subject]. 3. Depositions: With the Court's leave, we seek the opportunity to depose [Name of individual(s)] to obtain sworn testimony regarding [Explain the purpose or relevance of the deposition(s)]. 4. Expert Witnesses: In order to support our position, we seek authorization to engage expert witnesses who can provide professional opinions or evaluations on [Describe the specific areas of expertise]. By allowing us to propound additional discovery, we believe that the interests of both parties will be best served by uncovering essential facts and evidence necessary for an equitable resolution. Moreover, this joint motion bears testament to the parties' willingness to collaborate and ensure an efficient and productive legal process. For your convenience, we have attached a proposed discovery plan that outlines the areas we wish to explore and the timeline within which we propose to complete these additional discovery actions. We kindly request that you acknowledge receipt of this joint motion for leave to propound additional discovery within [indicate a reasonable timeframe]. Upon receipt, we anticipate that you will communicate your willingness to collaborate for the effective progression of this litigation. Thank you for your attention to this matter. We look forward to your favorable response and the Court's granting of our joint motion for leave to propound additional discovery. If you require any further information or have any questions, please do not hesitate to contact me. Yours sincerely, [Your Name] [Your Title/Position] [Your Company/Organization]

[Your Name] [Your Address] [City, State, ZIP Code] [Email Address] [Phone Number] [Date] [Recipient's Name] [Recipient's Address] [City, State, ZIP Code] Subject: Joint Motion for Leave to Propound Additional Discovery Dear [Recipient's Name], I hope this letter finds you well. I am writing to you on behalf of [Your Company/Organization] regarding the ongoing legal proceedings [Case Name/Number] pending in the [Court Name], pertaining to [Briefly describe the nature of the case]. As the discovery phase of the litigation proceeds, we have identified certain crucial pieces of information that require further investigation to ensure a fair and just resolution of the matter. Therefore, we hereby submit this joint motion for leave to propound additional discovery, as allowed under the legal framework prevailing in the state of New York. In accordance with the New York Civil Practice Law and Rules (CPR), specifically Rule 3101(f), which allows for additional discovery upon obtaining court permission, we respectfully request the Court's approval to undertake the following discovery actions: 1. Interrogatories: We propose to submit a set of written interrogatories to the opposing party to elicit specific information about [Describe the subject or area of information sought]. 2. Request for Production: We request permission to demand the opposing party to produce relevant documents, electronically stored information (ESI), records, or any other tangible evidence that pertains to [Specify the relevant subject]. 3. Depositions: With the Court's leave, we seek the opportunity to depose [Name of individual(s)] to obtain sworn testimony regarding [Explain the purpose or relevance of the deposition(s)]. 4. Expert Witnesses: In order to support our position, we seek authorization to engage expert witnesses who can provide professional opinions or evaluations on [Describe the specific areas of expertise]. By allowing us to propound additional discovery, we believe that the interests of both parties will be best served by uncovering essential facts and evidence necessary for an equitable resolution. Moreover, this joint motion bears testament to the parties' willingness to collaborate and ensure an efficient and productive legal process. For your convenience, we have attached a proposed discovery plan that outlines the areas we wish to explore and the timeline within which we propose to complete these additional discovery actions. We kindly request that you acknowledge receipt of this joint motion for leave to propound additional discovery within [indicate a reasonable timeframe]. Upon receipt, we anticipate that you will communicate your willingness to collaborate for the effective progression of this litigation. Thank you for your attention to this matter. We look forward to your favorable response and the Court's granting of our joint motion for leave to propound additional discovery. If you require any further information or have any questions, please do not hesitate to contact me. Yours sincerely, [Your Name] [Your Title/Position] [Your Company/Organization]