New York Sample Letter for Drafts of a Joint Motion for Additional Discovery and an Order Approving Same

• Category: Letters - Legal - Discovery
• State: Multi-State
• Control #: US-0093LTR
• 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] [Judge's Name] [Judge's Designation] [Name of the Court] [Court's Address] [City, State, ZIP] Re: Joint Motion for Additional Discovery and Order Approving Same Dear [Judge's Last Name], I hope this letter finds you in good health and high spirits. I am writing on behalf of [Plaintiff's Name] and [Defendant's Name], collectively referred to as "the Parties," to submit the joint motion for additional discovery as per the agreement reached between the Parties during a recent teleconference on [Date of Teleconference]. The joint motion is accompanied by a proposed Order which respectfully seeks your approval. In light of the complexity of the present case and the necessity for full and fair disclosure of all relevant information, the Parties have jointly agreed upon the need for further discovery beyond the scope initially anticipated. This joint motion aims to allow both parties sufficient time and resources to explore these potential avenues of evidence, ultimately enabling a thorough and just resolution of this matter. The proposed additional discovery encompasses the following: 1. Interrogatories: Both parties agree to serve and respond to an additional set of interrogatories, inquiring into specific aspects of the case that require further elucidation. These interrogatories will be served within [number of days]. 2. Requests for Production of Documents: To ensure the comprehensive assessment of the facts at hand, the Parties hereby agree to the submission and response of additional requests for production of documents within [number of days]. These documents will contribute significantly to the development of a complete factual record. 3. Depositions: The Parties mutually recognize the importance of taking additional depositions from key witnesses who have already been identified or may be identified during the course of the expanded discovery. The agreed-upon number of depositions is [number of depositions], to be scheduled within [number of days]. The Parties strongly believe that this additional discovery is crucial to adequately prepare for trial and to facilitate an efficient and equitable resolution. The anticipated benefits include a more complete understanding of the case, identification of all relevant facts, and the potential for alternative dispute resolution methods. Completing this additional discovery will ultimately serve to foster an environment conducive to achieving justice and fairness. Enclosed with this letter, please find the following documents: 1. Joint Motion for Additional Discovery: This document outlines the Parties' joint position endorsing the need for further discovery and elaborates on the specific areas targeted for additional exploration. 2. Proposed Order Approving Additional Discovery: The Parties have provided the court with a draft Order for consideration, which seeks approval for the additional discovery as described herein. We kindly request that the court schedule a conference or hearing at the earliest convenience to discuss the joint motion and proposed Order. Additionally, we respectfully ask for your guidance regarding any specific requirements or modifications that the court deems necessary. We appreciate your attention to this matter and look forward to your favorable ruling on our joint motion. Should you require any additional information or documentation, please do not hesitate to contact me at [Your Phone Number] or [Your Email Address]. Thank you for your time and consideration. Yours sincerely, [Your Name] [Your Bar Number]

[Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] [Judge's Name] [Judge's Designation] [Name of the Court] [Court's Address] [City, State, ZIP] Re: Joint Motion for Additional Discovery and Order Approving Same Dear [Judge's Last Name], I hope this letter finds you in good health and high spirits. I am writing on behalf of [Plaintiff's Name] and [Defendant's Name], collectively referred to as "the Parties," to submit the joint motion for additional discovery as per the agreement reached between the Parties during a recent teleconference on [Date of Teleconference]. The joint motion is accompanied by a proposed Order which respectfully seeks your approval. In light of the complexity of the present case and the necessity for full and fair disclosure of all relevant information, the Parties have jointly agreed upon the need for further discovery beyond the scope initially anticipated. This joint motion aims to allow both parties sufficient time and resources to explore these potential avenues of evidence, ultimately enabling a thorough and just resolution of this matter. The proposed additional discovery encompasses the following: 1. Interrogatories: Both parties agree to serve and respond to an additional set of interrogatories, inquiring into specific aspects of the case that require further elucidation. These interrogatories will be served within [number of days]. 2. Requests for Production of Documents: To ensure the comprehensive assessment of the facts at hand, the Parties hereby agree to the submission and response of additional requests for production of documents within [number of days]. These documents will contribute significantly to the development of a complete factual record. 3. Depositions: The Parties mutually recognize the importance of taking additional depositions from key witnesses who have already been identified or may be identified during the course of the expanded discovery. The agreed-upon number of depositions is [number of depositions], to be scheduled within [number of days]. The Parties strongly believe that this additional discovery is crucial to adequately prepare for trial and to facilitate an efficient and equitable resolution. The anticipated benefits include a more complete understanding of the case, identification of all relevant facts, and the potential for alternative dispute resolution methods. Completing this additional discovery will ultimately serve to foster an environment conducive to achieving justice and fairness. Enclosed with this letter, please find the following documents: 1. Joint Motion for Additional Discovery: This document outlines the Parties' joint position endorsing the need for further discovery and elaborates on the specific areas targeted for additional exploration. 2. Proposed Order Approving Additional Discovery: The Parties have provided the court with a draft Order for consideration, which seeks approval for the additional discovery as described herein. We kindly request that the court schedule a conference or hearing at the earliest convenience to discuss the joint motion and proposed Order. Additionally, we respectfully ask for your guidance regarding any specific requirements or modifications that the court deems necessary. We appreciate your attention to this matter and look forward to your favorable ruling on our joint motion. Should you require any additional information or documentation, please do not hesitate to contact me at [Your Phone Number] or [Your Email Address]. Thank you for your time and consideration. Yours sincerely, [Your Name] [Your Bar Number]