Subject: Request for Leave to Propound Additional Discovery — Joint Motion [Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] [Recipient's Name] [Recipient's Address] [City, State, ZIP] Re: Joint Motion for Leave to Propound Additional Discovery — [Case Name] Dear [Recipient's Name], I hope this letter finds you in good health and high spirits. I am writing to submit a Joint Motion for Leave to Propound Additional Discovery in the above-mentioned case. As parties to this lawsuit, we collectively request the court's permission to expand the discovery process in order to gather additional essential evidence vital to the resolution of this matter. Understanding the significance of accurate and complete discovery in a case of this nature, we believe that obtaining further information will provide a more comprehensive understanding of the facts at hand. As such, we intend to present this Motion to the Court to obtain leave to pursue additional discovery. We have outlined the specific reasons for seeking leave to propound additional discovery below: 1. Insufficient Response: Despite our earnest efforts to collect all relevant documentation and information during the initial discovery process, we have discovered that the responses received from the opposing party were inadequate and failed to address crucial aspects of the case. Consequently, further examination is necessary to ensure a fair and just resolution. 2. Newly Acquired Evidence: Since the completion of the initial discovery phase, we have obtained recently discovered evidence that is vital to our case but was not available at the time of the primary discovery process. This evidence, which includes [describe evidence briefly], is instrumental in supporting our claims and demands further investigation. 3. Unforeseen Complexity: As the case has progressed, unforeseen complexities have emerged that necessitate expanding the scope of discovery. These complexities have shed new light on the concerns, potential witnesses, and evidence that require immediate attention to maintain the integrity of the proceedings. 4. Proportionality and Necessity: We understand the court's concern for proportionality and the need to avoid undue burden or expense. Rest assured, any additional discovery we seek will be tightly focused and narrowly tailored to the essential elements of this case, ensuring a balanced approach that respects the principles of fairness and efficiency. Taking into consideration the above factors, we respectfully request that this Joint Motion for Leave to Propound Additional Discovery be granted at the earliest convenience. We firmly believe that allowing the parties to pursue further discovery will enable a comprehensive presentation of facts and ultimately lead to a fair and equitable resolution. If the Court requires any additional information or documentation in support of our request, kindly notify us, and we will promptly provide all necessary materials. Thank you for your attention to this matter. We look forward to the Court's favorable ruling on our Joint Motion, allowing us to pursue further discovery to better serve the interests of justice. Yours sincerely, [Your Name]
Wyoming Sample Letter conveying Joint Motion for Leave to Propound Additional Discovery
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FAQ
Rule 60 - Relief from a judgment or order (a) Corrections Based on Clerical Mistakes; Oversights and Omissions. The court may correct a clerical mistake or a mistake arising from oversight or omission whenever one is found in a judgment, order, or other part of the record.
(A) In addition to the disclosures required by paragraph (1), (1.1) or (1.2), a party must disclose to the other parties the identity of any witness it may use at trial to present evidence under Wyoming Rule of Evidence 702, 703, or 705. (B) Witnesses Who Must Provide a Written Report.
At any time more than 60 days after service of the complaint and at least 28 days before the date set for trial, any party may serve on an opposing party an offer to allow settlement or judgment on specified terms, with the costs then accrued.
On motion to compel discovery or to quash, the person from whom discovery is sought must show that the information sought is not reasonably accessible because of undue burden or cost.
This rule freely authorizes the taking of depositions under the same circumstances and by the same methods whether for the purpose of discovery or for the purpose of obtaining evidence.
The court on motion of a defendant may grant a new trial to that defendant if required in the interest of justice.
Under Rule 35, Wyoming Rules of Civil Procedure, whenever the physical or mental condition of a party is in controversy, the court in which the action is pending may order the party to submit to a physical or mental examination by a physician.
