[Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] [Recipient's Name] [Recipient's Address] [City, State, ZIP] Subject: West Virginia Sample Letter conveying Joint Motion for Leave to Propound Additional Discovery Dear [Recipient's Name], I hope this letter finds you in good health and high spirits. I am writing to convey a joint motion for leave to propound additional discovery in accordance with the laws and regulations of West Virginia. We, the parties involved in [case name], kindly request permission from the honorable court to undertake supplementary discovery efforts to ensure a fair and just resolution of the matter. As you may be aware, West Virginia follows the principles of fair and open discovery, allowing parties in a lawsuit to gather and exchange relevant information to substantiate their claims or defenses. In light of recent developments, it has become imperative to review additional evidence that has come to our attention. This evidence holds great potential in influencing the outcome of the case and merits careful examination. Our joint motion seeks permission to propound additional discovery requests to the opposing party. It is our belief that this step is crucial to uncovering vital facts, clarifying ambiguities, and strengthening our respective positions in this legal dispute. The proposed additional discovery includes but is not limited to: 1. Interrogatories: We request an extension to pose additional written questions to the opposing party regarding specific aspects of the case. These interrogatories will aid in unraveling key information and ensuring the completeness of the record. 2. Document Production Requests: We propose a wider scope for document production requests to gain access to additional records, reports, contracts, correspondence, or any other relevant material that might be germane to this case. 3. Depositions: We intend to take additional depositions of key witnesses involved in the matter, as it is crucial to secure their testimonies under oath. This step will enable us to fully comprehend their perspectives and evaluate the credibility and accuracy of their statements. By seeking leave from the court to undertake these additional discovery efforts, we demonstrate our commitment to due diligence and the pursuit of justice. We firmly believe that the information obtained through this process will not only clarify the issues at hand but also facilitate a fair and expeditious resolution of the dispute. We kindly request you to review this joint motion favorably, granting us the opportunity to further explore the facts surrounding this case. Furthermore, we assure you that we will conduct these additional discovery proceedings promptly and efficiently, with the utmost respect for the court's time and resources. Thank you for your attention to this matter. Should you require any further information or documents in support of this motion, please do not hesitate to contact me at [phone number] or [email address]. We kindly request a timely response to enable us to proceed accordingly. Yours sincerely, [Your Name]