Los Angeles, California Sample Letter for Plaintiff's Motion for Leave to File a Supplemental Memorandum [Your Name] [Your Address] [City, State, Zip Code] [Email Address] [Phone Number] [Date] [Judge's Name] [Judge's Designation] [Court's Name] [Court's Address] [City, State, Zip Code] Re: [Case Number]: Plaintiff's Motion for Leave to File a Supplemental Memorandum Dear Honorable [Judge's Last Name], I hope this letter finds you in good health and high spirits. I, [Your Name], on behalf of the plaintiff in the above-mentioned case, respectfully request your honorable court's permission to file a supplemental memorandum. Background: Provide a brief overview of the case and its current stage. State the issues at hand and the importance of generating additional information and arguments through a supplemental memorandum. Highlight the significance of this document in advocating for the plaintiff's rights and interests. Reasons for Seeking Leave to File a Supplemental Memorandum: 1. New Evidentiary Discoveries: Explain any recent discoveries or developments in the case that demand a presentation of additional evidence. Emphasize how these new findings will strengthen the plaintiff's position. 2. Change in Legal Landscape: Describe any changes in relevant laws, regulations, or legal precedents that have occurred since the last filing. Explain how these changes affect the plaintiff's case and the necessity of incorporating them into the arguments presented. 3. Addressing Defendants' Response: If the defendants have filed a response or counterclaim, highlight the specific points that need to be addressed through a supplemental memorandum. Explain the importance of a comprehensive response to protect the plaintiff's interests. 4. Clarification of Complex Issues: If there are intricate or complex legal issues involved in the case, indicate the need for further clarification through additional arguments and explanations. Describe how filing a supplemental memorandum will assist the court in understanding the complexities effectively. Proposed Contents for the Supplemental Memorandum: Provide an outline of the topics/issues that will be covered in the supplemental memorandum. Mention the specific arguments, evidence, or legal authorities that will be presented in support of the plaintiff's case. Make it clear that the proposed memorandum will be concise, relevant, and focused solely on addressing the newly discovered aspects or responding to the defendants' claims. Conclusion: Reiterate the significance of your request and express your utmost respect for the integrity and discretion of the court. Request an expedited consideration of the motion to file a supplemental memorandum to avoid any undue delay in the proceedings. Thank you for your attention and consideration of this matter. Should the court grant our motion, we assure you of our commitment to submitting the supplemental memorandum within the specified timeframe. Yours sincerely, [Your Name]