Oklahoma 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 Code] [Email Address] [Phone Number] [Date] [Name of the Clerk] [Court Name] [Court Address] [City, State, ZIP Code] Re: Joint Motion for Leave to Propound Additional Discovery Case: [Case Number] Plaintiff: [Plaintiff's Name] Defendant: [Defendant's Name] Dear [Clerk's Name], I am writing to file a Joint Motion for Leave to Propound Additional Discovery in the aforementioned case. As the Plaintiff and Defendant in this matter, we both believe that additional discovery is necessary to further clarify the issues at hand and ensure a fair and just resolution of this case. In accordance with the Oklahoma Rules of Civil Procedure, specifically Rule [relevant rule number], we kindly request permission from the Court to conduct further discovery beyond the initial scope outlined in the previous discovery requests. We firmly believe that the additional discovery will aid in the efficient resolution of this case, as it will provide crucial evidence, shed light on relevant facts, and help us better understand the opposing party's claims and defenses. By expanding the scope of discovery, we aim to obtain essential information, documents, and testimonies that will enable both parties to make informed decisions during subsequent proceedings. To ensure a comprehensive and holistic approach towards discovery, we propose the following additional methods and specific areas for discovery: 1. Interrogatories: We request permission to submit a set of written interrogatories to the opposing party, seeking detailed and specific responses relevant to the case. These interrogatories will delve into areas such as [keyword], [keyword], and [keyword], which are critical in establishing the facts and resolving the dispute. 2. Document Requests: We seek authorization to expand the document production requests to include a wider range of potentially relevant documents, such as [keyword], [keyword], and [keyword]. These documents will greatly aid in both parties' understanding of the facts, evidence, and key aspects of this dispute. 3. Depositions: We hereby request the ability to take additional depositions of key witnesses, experts, and other relevant individuals. These depositions will serve the purpose of obtaining sworn testimonies essential in presenting our respective cases comprehensively and in assisting the Court in arriving at a just conclusion. Our proposed additional discovery is intended to be fair, proportionate, and in the best interest of both parties, promoting a balance between the need for thorough fact-finding and the efficient progression of the litigation. In light of these factors, we respectfully request the Court's permission to file this Joint Motion for Leave to Propound Additional Discovery. We kindly ask that you promptly process and schedule a hearing on this motion, allowing both parties to present the need for expanded discovery and address any potential objections. Enclosed with this letter, please find two signed copies of the Joint Motion, adhering to the required formatting and including a proposed order granting the motion. We highly appreciate your attention to this matter and kindly request your prompt action in processing our motion. Should you require any additional information or have any questions, please do not hesitate to contact me at [phone number] or via email at [email address]. Thank you for your assistance, and we look forward to your favorable response. Sincerely, [Your Name] [Your Signature] Enclosure: — Signed Joint Motion for Leave to Propound Additional Discovery (2 copies) — Proposed Order