Texas Sample Letter for Joint Motion of Entry of Second Amended Scheduling Order Date: [Insert Date] [Your Name] [Your Address] [City, State, Zip Code] [Your Email Address] [Recipient's Name] [Recipient's Address] [City, State, Zip Code] Subject: Joint Motion of Entry of Second Amended Scheduling Order Dear [Recipient's Name], I hope this letter finds you well. I am writing to submit a joint motion for the entry of a second amended scheduling order in the case of [Case Name and Number], currently pending before the [Court Name] in the state of Texas. As the parties involved in this case, namely [Plaintiff's Name] (hereinafter referred to as "Plaintiff") and [Defendant's Name] (hereinafter referred to as "Defendant"), we have mutually agreed to amend the existing scheduling order to efficiently proceed with this matter and ensure a fair and just resolution. The purpose of this joint motion is to request the court's approval for changes in the scheduling order previously entered. This amended scheduling order will account for unforeseen circumstances and enable the parties to meet their obligations in an orderly fashion, considering the specifics of this case. The proposed second amended scheduling order seeks to modify certain deadlines and dates to better suit the needs and requirements of both parties. The amendments will allow for additional time for discovery, the identification of expert witnesses, and the submittal of expert reports. Moreover, it is vital to adjust the trial date to allocate sufficient time for any potential pretrial motions, hearings, and settlement conferences. We believe that the proposed amendments will not unduly prejudice any party and will, in fact, promote the expeditious resolution of this case. Both Plaintiff and Defendant are in agreement with the proposed changes and have signed the joint motion, which is enclosed herewith for your reference. Therefore, we kindly request the court's approval of this joint motion for the entry of the second amended scheduling order, in accordance with the applicable rules and procedures governing civil litigation in Texas. Thank you for your prompt attention to this matter. Should you require any additional information or have any questions, please do not hesitate to contact me at [Your Phone Number] or [Your Email Address]. Yours sincerely, [Your Name] Enclosure: Joint Motion for Entry of Second Amended Scheduling Order.