[Your Name] [Your Address] [City, State, ZIP Code] [Email Address] [Phone Number] [Date] Clerk of the Court [Name of the Court] [Address of the Court] [City, State, ZIP Code] Re: Joint Motion for Leave to Propound Additional Discovery Case: [Case Number] Plaintiff: [Plaintiff's Name] Defendant: [Defendant's Name] Dear Clerk, I hope this letter finds you well. I am writing to submit a Joint Motion for Leave to Propound Additional Discovery in the above-mentioned case. Kindly find the necessary documents attached to this correspondence and provide us with the appropriate instructions for submitting them for review by the Honorable Court. As per Rule [Rule Number] of the Virgin Islands Code of Civil Procedure, both the plaintiff and the defendant seek permission to propound additional discovery requests to, but not limited to, the opposing party. This joint motion aims to facilitate a fair and comprehensive exchange of information pertinent to this case. We believe that the additional discovery requests outlined within this motion are critical for both parties to acquire a complete understanding of the facts and merits of the case, ensuring a just and equitable outcome. In adherence to Rule [Rule Number], we have made every effort to confine our requests within the permissible limits, respecting the opposing party's prerogatives while adhering to the principles of due process. Please note that our previous discovery efforts have been exhausted, and it has become evident that further disclosure is essential. The proposed additional discovery requests will not impose an undue burden on either party, nor will they disrupt the orderly progression of the litigation. Enclosed within this letter, you will find the following documents necessary for the Court's review: 1. Joint Motion for Leave to Propound Additional Discovery — This details the reasons for seeking permission to conduct further discovery and provides a clear scope for the proposed additional requests. 2. Proposed Additional Discovery Requests — This document outlines the specific discovery requests the parties wish to make, including interrogatories, requests for production of documents, requests for admission, or any other necessary forms of discovery. Each request is succinctly described, supported by relevant legal authority and case law, and tailored to elicit pertinent information. 3. Proposed Order Granting Joint Motion for Leave to Propound Additional Discovery — This proposed order delineates the Court's authorization for the parties to undertake the additional discovery and specifies any necessary actions or limitations deemed appropriate by the Court. We kindly request your assistance with filing these documents in a timely manner. Additionally, please provide us with any further instructions or requirements needed to complete the filing process successfully. Thank you in advance for your attention to this matter. We look forward to the Court's favorable consideration of our Joint Motion for Leave to Propound Additional Discovery and appreciate your assistance in ensuring a smooth and efficient process. Should you have any questions or require further information, please do not hesitate to contact me at the provided phone number or email address. Sincerely, [Your Name]