[Your Name] [Your Address] [City, State, Zip Code] [Email Address] [Phone Number] [Date] [Clerk's Name] [Court's Name] [Court's Address] [City, State, Zip Code] Re: Joint Motion for Leave to Propound Additional Discovery Case: [Case Number] Dear [Clerk's Name], I hope this letter finds you well. I am writing to file a Joint Motion for Leave to Propound Additional Discovery in the above-mentioned case. We kindly request permission from the court to conduct supplemental discovery in order to fully assess all relevant facts and evidence pertaining to the case. To provide you with a comprehensive understanding of the nature of our motion, I would like to outline the key details and grounds for the joint motion: 1. Parties involved: [Plaintiff’s Name] and [Defendant’s Na—e] - [Plaintiff's Name]: [Briefly describe the plaintiff's role and interests in the case] — [Defendant's Name]: [Briefly describe the defendant's role and interests in the case] 2. Case overview: [Provide a brief summary of the case, highlighting its key aspects, issues, and legal claims involved] 3. Purpose of additional discovery: Our motion seeks to permit the parties to propound additional discovery requests in order to: — Obtain additional cruciaevidencenc— - Clarify ambiguities or discrepancies in the existing evidence — Uncover any new leads or information that may impact the outcome of the case — Ensure a fair and just resolution of the dispute 4. The necessity of additional discovery: [Explain why the requested discovery is necessary to effectively present the case, such as newly discovered evidence, witness availability, or relevance to specific issues] 5. Scope of additional discovery: [Specify the types of additional discovery sought, such as interrogatories, document requests, requests for admission, and depositions. Clearly mention the number of each type of request being sought] 6. Proposed timeline: [If applicable, mention any proposed deadlines for submitting requests, response times, and possible hearing dates] 7. Agreement between parties: [State that both parties involved in the case are in agreement regarding the necessity and scope of the additional discovery] 8. Certificates of Service: [Include a statement affirming that copies of this motion have been served to all relevant parties, their attorneys, and any other required recipients] 9. Joint Signature: [Include spaces below for both parties to sign and date the joint motion] Enclosed with this letter are the necessary documents, including the Joint Motion for Leave to Propound Additional Discovery, supporting affidavits (if any), and any other required attachments. We kindly request that you review the enclosed documents and file them accordingly with the court. Your assistance in this matter is greatly appreciated. Should you require any further information or documentation, please do not hesitate to contact me at [Phone Number] or [Email Address]. Thank you for your attention to this matter. Sincerely, [Your Name] Enclosure: — Joint Motion for Leave to Propound Additional Discovery — Supporting Affidavits (if any— - [List any other necessary attachments or documents]
Ohio Sample Letter to Clerk for filing Joint Motion for Leave to Propound Additional Discovery
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How to fill out Ohio Sample Letter To Clerk For Filing Joint Motion For Leave To Propound Additional Discovery?
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FAQ
The judge will either deny the motion to compel, order the opposition to provide the discovery by a deadline, or will grant in part and deny in part the motion, and will only require some of the discovery to be provided. Other sanctions may also be applied, including payment of attorney's fees or monetary fines.
We don't like Motions to Compel. Judges don't like them, and neither do the opposing parties we bring them against. But they are, sometimes, required to be brought in cases where you need information to make sure you know what facts, witnesses and documents are in a case prior to going to going to trial.
(b) Good Faith Efforts to Confer Before a party files a motion to compel a response to discovery, the party must make a good faith effort to confer with the person or party allegedly failing to properly respond to a request for discovery in an effort to secure information or material without action by the ALJ.
Deadline 45 days: Motion to Compel must be filed within 45 days from insufficient response [See Above].
When that happens, a party can file a motion to compel, asking the Court to order the opposing party to produce the contested documents or information. If a motion to compel is granted and the Court orders the information produced, failing to comply with that order can lead to serious consequences.
FILING THE MOTION FOR COURT HEARING File the motion with the Clerk of Court located in Room 35 on the ground floor of the Cuyahoga County Courthouse, 1 Lakeside Avenue, Cleveland, Ohio 44113. You will be required to pay a ?filing fee? to the Clerk of Court at the time you file the motion.
37. On notice to other parties and all affected persons, a party may move for an order compelling discovery. The motion shall include a certification that the movant has in good faith conferred or attempted to confer with the person or party failing to make discovery in an effort to obtain it without court action.
R. 11 governs the signing of pleadings, motions and other documents. For a ?willful? violation of this rule, an attorney or pro se party, upon motion of a party or upon the court's own motion, may be subjected to appropriate action, including an award to the opposing party of expenses and reasonable attorney fees.
