[Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [date] [Recipient's Name] [Recipient's Address] [City, State, ZIP] Subject: Joint Motion for Leave to Propound Additional Discovery — [Case Name] Dear [Recipient's Name], I hope this letter finds you well. I am writing to you in my capacity as [your position/title] on behalf of the respective parties involved, to submit a joint motion for leave to propound additional discovery in the aforementioned case, currently pending in the [Court Name]. We, the undersigned parties, have conferred and reached a mutual agreement to seek permission from the court to conduct additional discovery to further aid in the resolution of this matter. The purpose of this letter is to apprise the court of our intentions and request the necessary permission accordingly. [Provide a brief background of the case, including the names of the parties involved and a summary of the main issues.] Given the complex nature of this case, we believe that the additional discovery we seek will substantially contribute to clarifying relevant facts, refining legal arguments, and ensuring a fair and just resolution. The proposed additional discovery is crucial to uncovering the truth and addressing any outstanding questions and concerns, and it is in the best interest of all parties involved. [Specify the type(s) of additional discovery you are seeking. Some examples may include:] 1. Interrogatories: We request permission to submit a set of written questions to the other parties that seek to elicit specific information and clarifications necessary to further our understanding of the case. 2. Requests for Production of Documents: We seek to obtain additional documents, records, or tangible items that are relevant to the case and that have not yet been provided by the opposing parties. 3. Requests for Admissions: We intend to submit a series of statements requesting the opposing parties to admit or deny certain facts, aiming to narrow down the disputed issues and potentially facilitate a swifter resolution. 4. Depositions: We propose taking additional depositions of witnesses who possess crucial knowledge or may provide valuable insights into the case, as depositions conducted thus far have revealed new leads that necessitate further examination. [Include any supporting arguments or justifications for the necessity of the requested additional discovery, emphasizing the potential benefits it would bring to the case.] We have attached a proposed Joint Motion for Leave to Propound Additional Discovery for your review and consideration. We kindly request that you file this motion with the court at your earliest convenience, after making any necessary modifications or additions to suit your requirements. Please acknowledge receipt of this letter, and kindly indicate your agreement to file the joint motion. If you require any additional information or if there is a need for further discussion on this matter, please do not hesitate to contact me promptly. Thank you for your attention to this important matter. Sincerely, [Your Name]