[Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] [Recipient's Name] [Recipient's Position] [Recipient's Organization] [Organization Address] [City, State, ZIP] Re: Joint Motion for Leave to Propound Additional Discovery Dear [Recipient's Name], I am writing this letter on behalf of our client, [Your Client's Name], to submit a joint motion seeking leave from the court to propound additional discovery in the matter of [Case Name], currently pending before [Court Name], docket number [Docket Number]. Background: The purpose of this correspondence is to request permission to serve additional discovery requests on the opposing party, [Opposing Party's Name], to further develop the facts of this case comprehensively. We believe that the additional discovery will contribute significantly to the case and aid in resolving the disputed issues more efficiently. Motion Details: 1. Parties' Joint Agreement: We have reached a joint agreement with the opposing party, [Opposing Party's Name], to seek leave from the court to propound additional discovery and have shared this agreement in the attached joint motion. 2. Discovery Relevance: The proposed additional discovery is highly relevant to the facts at issue and will assist in clarifying various aspects of the case. It directly pertains to [describe the specific areas or topics for which you seek discovery]. 3. Case Impact: The requested additional discovery will enhance the parties' ability to prepare for trial and facilitate a fair and just resolution of the case. It will enable a more comprehensive assessment of the facts, encourage settlement discussions, and facilitate informed decision-making by both parties. 4. Proposed Discovery Methods: Attached to this motion is a proposed list of the new discovery methods we intend to employ, including interrogatories, requests for production of documents, and requests for admissions. We have carefully crafted these methods to ensure they target the specific information needed to support our case effectively. Conclusion: We kindly request that the court grant our joint motion for leave to propound additional discovery in a timely manner, enabling us to further explore the facts of this case. This motion reflects the agreement and mutual consent of both parties and the intention to cooperatively and efficiently proceed with the lawsuit. If necessary, we are more than willing to attend a hearing or provide any additional information the court or opposing party may require to facilitate the resolution of this joint motion. Thank you for your attention to this matter, and we look forward to a favorable resolution. Sincerely, [Your Name] [Your Designation] [Your Law Firm] [Law Firm Address] [City, State, ZIP] [Email Address] [Phone Number] Enclosure (Joint Motion for Leave to Propound Additional Discovery)
Alaska Sample Letter conveying Joint Motion for Leave to Propound Additional Discovery
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