Collin Texas Sample Letter to Clerk for filing Joint Motion for Leave to Propound Additional Discovery

• Category: Letters - Legal - Motions
• State: Multi-State
• County: Collin
• Control #: US-0863LTR
• Format: Word; Rich Text

Description

This form is a sample letter in Word format covering the subject matter of the title of the form. [Your Name] [Your Address] [City, State, Zip Code] [Email Address] [Phone Number] [Date] [Name of Clerk] [Name of Court] [Address] [City, State, Zip Code] Subject: Joint Motion for Leave to Propound Additional Discovery Dear [Name of Clerk], I hope this letter finds you in good health. I am writing to file a Joint Motion for Leave to Propound Additional Discovery in the case of [Case Name and Number] currently pending before the honorable court. We, as the parties [Plaintiff's Name] and [Defendant's Name], both request the court's permission to serve additional discovery requests beyond the limits stated in the scheduling order set forth in this case. As per Rule _____ (Rule Number) of the [Court's Name] Rules of Civil Procedure, we seek leave of the court to propound the following additional discovery to the opposing party: 1. [Description of the first set of additional discovery requests] 2. [Description of the second set of additional discovery requests] 3. [Description of the third set of additional discovery requests] Please find attached a copy of the proposed additional interrogatories, requests for production of documents, and requests for admission we intend to serve upon the opposing party. These discovery requests are essential for clarifying key issues and gathering all relevant information to ensure a fair and just resolution of this case. Additionally, we have made reasonable efforts to confer and obtain the opposing party's consent for the filing of this joint motion. However, as the parties were unable to reach a mutual agreement regarding the additional discovery, we seek the court's intervention in providing us with the necessary leave to propound the aforementioned discovery. Considering the significance of obtaining this additional discovery, we kindly request an expedited hearing on this joint motion. We assure you that we will cooperate fully in complying with any orders or directives issued by the court. Thank you for your attention to this matter. Should you require any additional information or documentation, please do not hesitate to contact me at [Phone Number] or [Email Address]. I look forward to your prompt response. Sincerely, [Your Name] [Your Role/Title (e.g., Attorney for Plaintiff)] [Attorney's Bar Number, if applicable]

[Your Name] [Your Address] [City, State, Zip Code] [Email Address] [Phone Number] [Date] [Name of Clerk] [Name of Court] [Address] [City, State, Zip Code] Subject: Joint Motion for Leave to Propound Additional Discovery Dear [Name of Clerk], I hope this letter finds you in good health. I am writing to file a Joint Motion for Leave to Propound Additional Discovery in the case of [Case Name and Number] currently pending before the honorable court. We, as the parties [Plaintiff's Name] and [Defendant's Name], both request the court's permission to serve additional discovery requests beyond the limits stated in the scheduling order set forth in this case. As per Rule _____ (Rule Number) of the [Court's Name] Rules of Civil Procedure, we seek leave of the court to propound the following additional discovery to the opposing party: 1. [Description of the first set of additional discovery requests] 2. [Description of the second set of additional discovery requests] 3. [Description of the third set of additional discovery requests] Please find attached a copy of the proposed additional interrogatories, requests for production of documents, and requests for admission we intend to serve upon the opposing party. These discovery requests are essential for clarifying key issues and gathering all relevant information to ensure a fair and just resolution of this case. Additionally, we have made reasonable efforts to confer and obtain the opposing party's consent for the filing of this joint motion. However, as the parties were unable to reach a mutual agreement regarding the additional discovery, we seek the court's intervention in providing us with the necessary leave to propound the aforementioned discovery. Considering the significance of obtaining this additional discovery, we kindly request an expedited hearing on this joint motion. We assure you that we will cooperate fully in complying with any orders or directives issued by the court. Thank you for your attention to this matter. Should you require any additional information or documentation, please do not hesitate to contact me at [Phone Number] or [Email Address]. I look forward to your prompt response. Sincerely, [Your Name] [Your Role/Title (e.g., Attorney for Plaintiff)] [Attorney's Bar Number, if applicable]