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] [Recipient's Name] [Recipient's Address] [City, State, ZIP Code] Re: 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 as counsel for [Your Party] in the above-mentioned case. We, in conjunction with opposing counsel, have reached an agreement to jointly file a Motion for Leave to Propound Additional Discovery in accordance with the Texas Rules of Civil Procedure. As you are aware, the purpose of this joint motion is to request permission from the court to conduct additional discovery in order to gather further relevant and necessary information related to our case. The proposed additional discovery seeks to fill the gaps in our knowledge and better prepare our respective parties for the upcoming trial. In accordance with Texas law and the rules governing civil procedures, we respectfully request the court to grant us leave to propound additional discovery. It is essential that we be allowed the opportunity to explore certain crucial aspects of the case, which have arisen after the initial discovery phase. We have attached a copy of the proposed Joint Motion for Leave to Propound Additional Discovery, which outlines the details and specifics of the requested additional discovery. The joint motion proposes several methods of additional discovery, including but not limited to verified interrogatories, requests for admission, and production of documents. We believe that the discovery sought in this motion is reasonable, necessary, and directly relevant to our case. The additional information we seek will significantly contribute to a fair and just resolution of the matter, promoting the principles of justice and due process. Should the court require any additional information or documentation to consider our motion, we kindly request you to inform us promptly. We remain open to resolving any concerns or uncertainties prior to the scheduled hearing. As counsel working towards an amicable resolution, we sincerely hope that this joint motion will receive your full support and recommendation to the court. Our intention is to foster an efficient and transparent legal process that upholds the interests of both parties and facilitates the proper administration of justice. Thank you for your attention to this matter. We appreciate your time and cooperation. Should you have any questions or require further clarification, please do not hesitate to contact me at [Phone Number] or [Email Address]. Yours sincerely, [Your Name] [Your Law Firm] [Your Law Firm's Address] [City, State, ZIP Code]
[Your Name] [Your Address] [City, State, ZIP Code] [Email Address] [Phone Number] [Date] [Recipient's Name] [Recipient's Address] [City, State, ZIP Code] Re: 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 as counsel for [Your Party] in the above-mentioned case. We, in conjunction with opposing counsel, have reached an agreement to jointly file a Motion for Leave to Propound Additional Discovery in accordance with the Texas Rules of Civil Procedure. As you are aware, the purpose of this joint motion is to request permission from the court to conduct additional discovery in order to gather further relevant and necessary information related to our case. The proposed additional discovery seeks to fill the gaps in our knowledge and better prepare our respective parties for the upcoming trial. In accordance with Texas law and the rules governing civil procedures, we respectfully request the court to grant us leave to propound additional discovery. It is essential that we be allowed the opportunity to explore certain crucial aspects of the case, which have arisen after the initial discovery phase. We have attached a copy of the proposed Joint Motion for Leave to Propound Additional Discovery, which outlines the details and specifics of the requested additional discovery. The joint motion proposes several methods of additional discovery, including but not limited to verified interrogatories, requests for admission, and production of documents. We believe that the discovery sought in this motion is reasonable, necessary, and directly relevant to our case. The additional information we seek will significantly contribute to a fair and just resolution of the matter, promoting the principles of justice and due process. Should the court require any additional information or documentation to consider our motion, we kindly request you to inform us promptly. We remain open to resolving any concerns or uncertainties prior to the scheduled hearing. As counsel working towards an amicable resolution, we sincerely hope that this joint motion will receive your full support and recommendation to the court. Our intention is to foster an efficient and transparent legal process that upholds the interests of both parties and facilitates the proper administration of justice. Thank you for your attention to this matter. We appreciate your time and cooperation. Should you have any questions or require further clarification, please do not hesitate to contact me at [Phone Number] or [Email Address]. Yours sincerely, [Your Name] [Your Law Firm] [Your Law Firm's Address] [City, State, ZIP Code]