Bronx New York Sample Letter for Joint Motion of Entry of Second Amended Scheduling Order

• Category: Letters - Legal - Motions
• State: Multi-State
• County: Bronx
• Control #: US-0865LTR
• 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] [Recipient's Name] [Recipient's Address] [City, State, ZIP Code] Re: Joint Motion of Entry of Second Amended Scheduling Order Dear [Recipient's Name], I hope this correspondence finds you well. As part of the ongoing legal proceedings in the case of [Case Name], we, the undersigned, write to submit this Joint Motion of Entry of Second Amended Scheduling Order. This motion seeks to modify the existing scheduling order in order to address unforeseen circumstances and ensure the fair and efficient administration of justice. The current scheduling order, dated [date], has become impracticable due to [reason for modification, such as the discovery of new evidence, the unavailability of key witnesses, changes in legal strategies, etc.]. To properly accommodate these emergent factors, it is necessary to submit this joint motion for the entry of a second amended scheduling order. The proposed amendments to the scheduling order include the following: 1. Extension of discovery deadlines: Due to the newly discovered evidence, both parties require additional time to complete the necessary investigations. Thus, we propose extending the discovery deadline by [proposed duration, e.g., 60 days] to allow sufficient time for comprehensive discovery. 2. Expert witness disclosures: Given the revised timeline, we suggest modifying the deadline for expert witness disclosures in adherence to the Federal Rules of Civil Procedure. This extension would help both parties prepare adequately and make informed decisions. 3. Pretrial conference and trial dates: In light of the adjustments made to the discovery process, it is imperative to reschedule the pretrial conference and trial dates accordingly. We propose discussing the availability of the court and parties involved to determine suitable alternative dates. 4. Any other necessary modifications: It is anticipated that other aspects of the scheduling order, such as briefing schedules, filing dates, or hearings, may require modifications in light of the aforementioned changes. We trust that the Court will consider these adjustments in the interest of fairness and the orderly progression of this case. We affirm that this request is made in good faith and has been jointly agreed upon by both parties. Attached herewith is the proposed Second Amended Scheduling Order for your review. We kindly request your prompt attention to this matter in order to minimize any disruption to the proceedings. Considering the nature of the proposed amendments to the original scheduling order, we believe it is in the best interest of all parties and the Court to grant this joint motion. We remain open to discussing any potential concerns or questions you may have regarding these proposed modifications. Thank you for your understanding and cooperation. We eagerly await your favorable response to this Joint Motion of Entry of Second Amended Scheduling Order. Sincerely, [Your Name] [Your Law Firm (if applicable)]

[Your Name] [Your Address] [City, State, ZIP Code] [Email Address] [Phone Number] [Date] [Recipient's Name] [Recipient's Address] [City, State, ZIP Code] Re: Joint Motion of Entry of Second Amended Scheduling Order Dear [Recipient's Name], I hope this correspondence finds you well. As part of the ongoing legal proceedings in the case of [Case Name], we, the undersigned, write to submit this Joint Motion of Entry of Second Amended Scheduling Order. This motion seeks to modify the existing scheduling order in order to address unforeseen circumstances and ensure the fair and efficient administration of justice. The current scheduling order, dated [date], has become impracticable due to [reason for modification, such as the discovery of new evidence, the unavailability of key witnesses, changes in legal strategies, etc.]. To properly accommodate these emergent factors, it is necessary to submit this joint motion for the entry of a second amended scheduling order. The proposed amendments to the scheduling order include the following: 1. Extension of discovery deadlines: Due to the newly discovered evidence, both parties require additional time to complete the necessary investigations. Thus, we propose extending the discovery deadline by [proposed duration, e.g., 60 days] to allow sufficient time for comprehensive discovery. 2. Expert witness disclosures: Given the revised timeline, we suggest modifying the deadline for expert witness disclosures in adherence to the Federal Rules of Civil Procedure. This extension would help both parties prepare adequately and make informed decisions. 3. Pretrial conference and trial dates: In light of the adjustments made to the discovery process, it is imperative to reschedule the pretrial conference and trial dates accordingly. We propose discussing the availability of the court and parties involved to determine suitable alternative dates. 4. Any other necessary modifications: It is anticipated that other aspects of the scheduling order, such as briefing schedules, filing dates, or hearings, may require modifications in light of the aforementioned changes. We trust that the Court will consider these adjustments in the interest of fairness and the orderly progression of this case. We affirm that this request is made in good faith and has been jointly agreed upon by both parties. Attached herewith is the proposed Second Amended Scheduling Order for your review. We kindly request your prompt attention to this matter in order to minimize any disruption to the proceedings. Considering the nature of the proposed amendments to the original scheduling order, we believe it is in the best interest of all parties and the Court to grant this joint motion. We remain open to discussing any potential concerns or questions you may have regarding these proposed modifications. Thank you for your understanding and cooperation. We eagerly await your favorable response to this Joint Motion of Entry of Second Amended Scheduling Order. Sincerely, [Your Name] [Your Law Firm (if applicable)]