This form is a sample letter in Word format covering the subject matter of the title of the form.
Subject: Request for Filing Joint Motion to Seek Additional Discovery — Texas Dear [Clerk's Name], I hope this letter finds you well. I am writing to submit a request for filing a Joint Motion for Leave to Propound Additional Discovery in accordance with the rules and regulations of the State of Texas. As parties to a legal case pending before the [Court Name], both the plaintiff and defendant recognize the need for further evidence to ensure a fair and just resolution of this matter. Our intent is to gather information that is crucial to the discovery process and ultimately assist in the pursuit of truth and justice. In line with the Texas Rules of Civil Procedure, more specifically, Rule [insert relevant rule number], we assert that the additional discovery we seek is necessary for the proper preparation of our case. After careful evaluation of the existing evidence and discussions between the involved parties, we firmly believe that this motion represents a sincere effort to ensure a complete and equitable exchange of information. Outlined below are the details of the additional discovery we propose: 1. Specific Discovery Requests: [Provide a concise summary of the nature and scope of the additional discovery being sought. Specify the type of documents, testimonies, or other related evidence that the parties deem crucial to the case.] 2. Reasons for Seeking Additional Discovery: [Elaborate on the reasons why the parties believe the proposed discovery is necessary. It could include the need to clarify factual disputes, substantiate claims or defenses, or uncover new evidence that would affect the outcome of the case.] 3. Relevance and Importance: [Explain the relevance and importance of the sought-after discoveries, emphasizing how they will help the parties better understand the issues at hand, assist in narrowing the issues for trial, or avoid unnecessary delay or expense.] 4. Efforts Toward Resolution: [Share any previous attempts made on behalf of both parties to resolve the matter outside the courtroom, if applicable. Describe the good faith efforts undertaken by the parties to discuss the potential of additional discovery, highlighting any agreements or disagreements that have arisen.] 5. Proposed Timeline: [Specify the timeline for the proposed additional discovery, including the estimated duration necessary for completion, the commencement date, and any potential impact on the trial schedule.] In light of the above, we kindly request your assistance in processing this Joint Motion for Leave to Propound Additional Discovery. Enclosed with this letter, please find the necessary documents, including copies of the proposed discovery requests, relevant supporting documents, and any required filing fees. If any additional documents are required, please let us know, and we will promptly provide them to ensure a complete submission. We trust that you will review this request promptly and diligently. Your attention and cooperation in this matter are greatly appreciated. Should you have any questions or require further clarification, please feel free to contact the undersigned or our legal representation. Thank you in advance for your time, assistance, and consideration. Sincerely, [Your Name] [Your Address] [City, State, ZIP Code] [Phone Number] [Email Address] cc: [Opposing Party's Counsel] [Judge's Chambers] (if required)
Subject: Request for Filing Joint Motion to Seek Additional Discovery — Texas Dear [Clerk's Name], I hope this letter finds you well. I am writing to submit a request for filing a Joint Motion for Leave to Propound Additional Discovery in accordance with the rules and regulations of the State of Texas. As parties to a legal case pending before the [Court Name], both the plaintiff and defendant recognize the need for further evidence to ensure a fair and just resolution of this matter. Our intent is to gather information that is crucial to the discovery process and ultimately assist in the pursuit of truth and justice. In line with the Texas Rules of Civil Procedure, more specifically, Rule [insert relevant rule number], we assert that the additional discovery we seek is necessary for the proper preparation of our case. After careful evaluation of the existing evidence and discussions between the involved parties, we firmly believe that this motion represents a sincere effort to ensure a complete and equitable exchange of information. Outlined below are the details of the additional discovery we propose: 1. Specific Discovery Requests: [Provide a concise summary of the nature and scope of the additional discovery being sought. Specify the type of documents, testimonies, or other related evidence that the parties deem crucial to the case.] 2. Reasons for Seeking Additional Discovery: [Elaborate on the reasons why the parties believe the proposed discovery is necessary. It could include the need to clarify factual disputes, substantiate claims or defenses, or uncover new evidence that would affect the outcome of the case.] 3. Relevance and Importance: [Explain the relevance and importance of the sought-after discoveries, emphasizing how they will help the parties better understand the issues at hand, assist in narrowing the issues for trial, or avoid unnecessary delay or expense.] 4. Efforts Toward Resolution: [Share any previous attempts made on behalf of both parties to resolve the matter outside the courtroom, if applicable. Describe the good faith efforts undertaken by the parties to discuss the potential of additional discovery, highlighting any agreements or disagreements that have arisen.] 5. Proposed Timeline: [Specify the timeline for the proposed additional discovery, including the estimated duration necessary for completion, the commencement date, and any potential impact on the trial schedule.] In light of the above, we kindly request your assistance in processing this Joint Motion for Leave to Propound Additional Discovery. Enclosed with this letter, please find the necessary documents, including copies of the proposed discovery requests, relevant supporting documents, and any required filing fees. If any additional documents are required, please let us know, and we will promptly provide them to ensure a complete submission. We trust that you will review this request promptly and diligently. Your attention and cooperation in this matter are greatly appreciated. Should you have any questions or require further clarification, please feel free to contact the undersigned or our legal representation. Thank you in advance for your time, assistance, and consideration. Sincerely, [Your Name] [Your Address] [City, State, ZIP Code] [Phone Number] [Email Address] cc: [Opposing Party's Counsel] [Judge's Chambers] (if required)