Subject: Pennsylvania Sample Letter to Clerk for Filing Joint Motion for Leave to Propound Additional Discovery in a Civil Case Dear Clerk of the Court, I hope this letter finds you well. I am writing to formally request the filing of a Joint Motion for Leave to Propound Additional Discovery in the above-mentioned civil case pending before this honorable court. In accordance with the Pennsylvania Rules of Civil Procedure, specifically Rule XXX (insert relevant rule number), we, the undersigned parties (Plaintiff's Name and Defendant's Name), hereby jointly move for leave to propound additional discovery requests outside the normal time frame allowed under the Rules. The purpose of this motion is to facilitate the obtainment of critical evidence that has recently come to our attention and is crucial to the preparation of this case. Our grounds for this joint motion are as follows: 1. Newly Discovered Evidence: We have recently discovered new evidence that is material and relevant to the issues in dispute. This evidence could significantly impact the outcome of the case if admitted. 2. Good Cause: There is good cause to allow the additional discovery as it is essential to a fair and just resolution of this matter. The newly discovered evidence was not within the knowledge or control of any party prior to its discovery, and its exclusion would result in manifest injustice. 3. Timeliness: Despite the fact that this motion is filed outside the normal discovery period, it should be granted as soon as possible to avoid any undue delay in the proceedings. 4. Agreement between Parties: We, the undersigned parties, jointly and mutually agree to this motion and request that the court grant us leave to propound additional discovery. Therefore, we respectfully request that a hearing be scheduled at the earliest convenient date before the court to consider this motion. We also kindly request that the necessary copies of this Joint Motion for Leave to Propound Additional Discovery be filed and that we be promptly notified of any further required documentation or fees. Should you require any additional information or have any questions about this motion, please do not hesitate to contact me at the address or phone number provided below. Thank you for your attention to this matter. We look forward to a favorable response from the court. Yours sincerely, [Your Name] [Your Address] [City, State, ZIP Code] [Your Phone Number] [Your Email Address] cc: [Opposing Counsel] [Judge's Name]