San Antonio Texas Sample Letter for Joint Motion of Entry of Second Amended Scheduling Order

• Category: Letters - Legal - Motions
• State: Multi-State
• City: San Antonio
• 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] [Email Address] [Phone Number] [Date] [Recipient's Name] [Recipient's Address] [City, State, ZIP] Subject: Second Amended Scheduling Order — Joint Motion for Entry Dear [Recipient's Name], I hope this letter finds you in good health and high spirits. I am writing to jointly move for the entry of the Second Amended Scheduling Order in the case of [Case Name/Number]. We believe that the proposed changes to the current scheduling order will streamline the litigation process and ensure a fair and timely resolution. As stipulated in our previous discussions, the parties involved in this litigation have encountered unforeseen circumstances that warrant the need for adjustments to the existing scheduling order. These changes are imperative to better accommodate the evolving complexity of this case and the discovery process. The proposed amendments consider the availability of key witnesses, expert reports, and the gathering of crucial evidence that may impact the direction and outcome of this litigation. Accordingly, we respectfully request the court's approval to modify the following aspects of the current scheduling order: 1. Discovery Deadlines: a. Extend the deadline for the completion of all fact discovery to [new date]. b. Extend the deadline for expert witness disclosures to [new date]. c. Extend the deadline for expert rebuttal disclosures to [new date]. d. Extend the deadline for the completion of all expert discovery to [new date]. 2. Motion Deadlines: a. Extend the deadline for dispositive motions to [new date]. b. Extend the deadline for Dauber motions to [new date]. 3. Pretrial Conference and Trial Dates: a. Request an adjustment to the pretrial conference date to [new date]. b. Request an adjustment to the trial commencement date to [new date]. We kindly ask for the court's cooperation and understanding in granting this joint motion for entry of the Second Amended Scheduling Order. By doing so, all parties will have ample time to prepare their cases thoroughly, exchange necessary information, and sufficiently explore the legal matters associated with this litigation. We believe that the proposed amendments will bring about a fair and efficient resolution to this case. Furthermore, by promptly addressing these changes, we aim to prevent any undue delay or prejudice to the involved parties. Please find attached the proposed Second Amended Scheduling Order for your review and consideration. We kindly request that you review and sign the order accordingly once approved. Thank you for your attention to this matter. We look forward to your favorable response to this joint motion. Feel free to reach out to me should you have any questions or require additional information. Yours sincerely, [Your Name]

[Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] [Recipient's Name] [Recipient's Address] [City, State, ZIP] Subject: Second Amended Scheduling Order — Joint Motion for Entry Dear [Recipient's Name], I hope this letter finds you in good health and high spirits. I am writing to jointly move for the entry of the Second Amended Scheduling Order in the case of [Case Name/Number]. We believe that the proposed changes to the current scheduling order will streamline the litigation process and ensure a fair and timely resolution. As stipulated in our previous discussions, the parties involved in this litigation have encountered unforeseen circumstances that warrant the need for adjustments to the existing scheduling order. These changes are imperative to better accommodate the evolving complexity of this case and the discovery process. The proposed amendments consider the availability of key witnesses, expert reports, and the gathering of crucial evidence that may impact the direction and outcome of this litigation. Accordingly, we respectfully request the court's approval to modify the following aspects of the current scheduling order: 1. Discovery Deadlines: a. Extend the deadline for the completion of all fact discovery to [new date]. b. Extend the deadline for expert witness disclosures to [new date]. c. Extend the deadline for expert rebuttal disclosures to [new date]. d. Extend the deadline for the completion of all expert discovery to [new date]. 2. Motion Deadlines: a. Extend the deadline for dispositive motions to [new date]. b. Extend the deadline for Dauber motions to [new date]. 3. Pretrial Conference and Trial Dates: a. Request an adjustment to the pretrial conference date to [new date]. b. Request an adjustment to the trial commencement date to [new date]. We kindly ask for the court's cooperation and understanding in granting this joint motion for entry of the Second Amended Scheduling Order. By doing so, all parties will have ample time to prepare their cases thoroughly, exchange necessary information, and sufficiently explore the legal matters associated with this litigation. We believe that the proposed amendments will bring about a fair and efficient resolution to this case. Furthermore, by promptly addressing these changes, we aim to prevent any undue delay or prejudice to the involved parties. Please find attached the proposed Second Amended Scheduling Order for your review and consideration. We kindly request that you review and sign the order accordingly once approved. Thank you for your attention to this matter. We look forward to your favorable response to this joint motion. Feel free to reach out to me should you have any questions or require additional information. Yours sincerely, [Your Name]