Wake North Carolina Sample Letter to Clerk for filing Joint Motion for Leave to Propound Additional Discovery

State:
Multi-State
County:
Wake
Control #:
US-0863LTR
Format:
Word; 
Rich Text
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Description

This form is a sample letter in Word format covering the subject matter of the title of the form.

Subject: Request for Joint Motion for Leave to Propound Additional Discovery — Wake North Carolina Dear Clerk of Court, I hope this letter finds you well. I am writing to request the filing of a Joint Motion for Leave to Propound Additional Discovery in the [insert case name and number] pending before the honorable court in Wake County, North Carolina. This joint motion is being filed by both the plaintiff and defendant, indicating their mutual agreement and consent to obtain additional discovery beyond the initial discovery phase. This motion aims to facilitate a fair and just resolution of the case by allowing both parties to gather essential information to support their respective claims or defenses. As per Rule [insert relevant rule number] of the North Carolina Rules of Civil Procedure, parties are entitled to seek leave from the court to propound additional discovery requests beyond the scope of initial disclosures. In light of the evolving nature of litigation, it becomes necessary for the parties to request supplemental discovery to ensure a comprehensive understanding of the facts at hand, ultimately serving the goal of seeking a just and efficient resolution. By filing this Joint Motion for Leave to Propound Additional Discovery, the parties acknowledge that there is a legitimate need to obtain further information, documents, interrogatories, requests for admission, or any other relevant discovery tools, which will assist in clarifying and substantiating their positions. Additionally, this motion demonstrates the willingness of both parties to cooperate and maintain transparency throughout the litigation process, respecting the principles of fairness and equal access to evidence. We kindly request the Clerk of Court to accept and file the attached Joint Motion for Leave to Propound Additional Discovery, along with any supporting documents or exhibits that may accompany it. We have ensured the document complies with the necessary formatting requirements and includes all relevant information as required by the court. Should you require any further information or documentation, please do not hesitate to contact our respective counsels or the undersigned. We greatly appreciate your attention to this matter and look forward to a prompt resolution of our request. Thank you for your time and consideration. Sincerely, [Your Name] [Your Address] [City, State, Zip Code] [Phone Number] [Email Address]

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FAQ

The process of delivering, or making available for review, documents in response to a request for documents, such as a request for production and a subpoena. A request for documents may call for the production of paper (hard copy) documents and electronically stored information (ESI).

Take your completed packet to the Clerk's Office (Civil Filing Department), Room 3725. This is where you file your motion and pay the required $20 filing fee. 3. Request that the Judge sign the Order to Appear and Show Cause.

Filing the Documents Take the original and two (2) copies of the Motion to the Civil Division of the Clerk of Superior Court's office in the county where your case is filed. The Clerk will stamp each Motion filed, place the original in the Court file and return two (2) copies of the filed document to you.

California law places strict limits on the number of discovery requests a party can make. In a limited civil case (cases less than $25,000) you may ask each party only 35 questions total, whether they are form interrogatories, special interrogatories, requests for admission, or requests for production.

How to Write a Kick-Ass Motion Make an Outline.Keep Your Motion Simple.Maintain Credibility.Mind Your Citations.Focus on Facts.Keep Your Intro Short.Respect the Opposition.Write in English, Not Legalese.

In responding to Requests for Production of documents you have three response choices (1) agree to produce (C.C.P. §2031.220); (2) state that after a diligent search and a reasonable inquiry you have no documents (C.C.P. §2031.230) or (3) object (C.C.P. §2031.240).

What Is a Request for Production of Documents? A request for production is a discovery device used to gain access to documents, electronic data, and physical items held by an opposing party in a legal matter. The aim is to gain insight into any relevant evidence that the opposing party holds.

How to present a losing objection: Make it a lead-off general objection. Object to anything that is not relevant to the subject matter (no longer the standard) or not likely to lead to admissible evidence (no longer the standard). Don't say if anything is being withheld on the basis of the objection.

Overall, a private right of action literally means that a private citizen has the right to take action.

For document discovery to be effective, it needs to be well planned. Have a strategy.Adjust the scope of your requests to the questions at issue.Send clear requests.Always consider how your client would be prepared to respond to similar requests.Make your objections clear and specific.

More info

Appointment shall be filed in the Office of the Clerk of Circuit Court. A trial court may not grant more relief than requested in the motion for summary judgment.24 Because a party can move for partial summary. Requirements to file your Petition (Request) with this Court.

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Wake North Carolina Sample Letter to Clerk for filing Joint Motion for Leave to Propound Additional Discovery