[Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] [Judge's Name] [Judge's Designation] [Court's Name] [Court's Address] [City, State, ZIP] Re: [Case Name], Case No. [Case Number] Dear Honorable [Judge's Last Name], I hope this letter finds you in good health and high spirits. I am writing on behalf of the plaintiff in the aforementioned case, [Case Name], to seek the court's permission to file a Supplemental Memorandum in order to address newly discovered evidence that significantly impacts the outcome of the case. Background: [Provide a brief overview of the litigation process, including key dates and events leading up to the need for the supplemental memorandum.] Reasons for Requesting the Supplemental Memorandum: Upon diligent review of the case records, it has come to our attention that new evidence has recently become available, which directly relates to the central issues of this case. This evidence includes [describe the nature of the evidence and its relevance to the case]. The Plaintiff firmly believes that this evidence has significant bearing on the claims presented and will substantially strengthen their position. Importance of the Supplemental Memorandum: The newly discovered evidence fundamentally alters the landscape of the case and necessitates a comprehensive evaluation of its legal implications. It is vital that the court considers this evidence, as disregarding it could result in an unfair outcome and potentially undermine the integrity of justice. To ensure a just and equitable resolution, the Plaintiff kindly requests the court's permission to submit a Supplemental Memorandum elaborating on the impact of the newly discovered evidence. Legal Basis: Granting leave to file a Supplemental Memorandum is within the court's discretion, pursuant to [cite relevant court rule or precedent here]. Our request adheres to the legal framework established by the Connecticut judiciary and aligns with the principles of fairness, due process, and fundamental justice. Proposed Schedule: To promptly address the newly discovered evidence, the Plaintiff proposes the following schedule: 1. Submission of the Supplemental Memorandum: [Specify a reasonable deadline, typically within 14 days from receiving the court's permission] 2. Response from the Defendant: [Allow a reasonable time for the defendant to review the memorandum and submit their response, typically within 14 days] 3. Oral Argument: [Suggest a suitable date and time for an oral argument to further discuss the Supplemental Memorandum, if deemed necessary by the court] Conclusion: In light of the newly discovered evidence and its potential impact on the outcome of this case, the Plaintiff respectfully requests the court's permission to file a Supplemental Memorandum. This will ensure a comprehensive and balanced evaluation of the evidence, allowing the court to make a fair and informed decision. The proposed schedule outlined above will enable timely consideration of the additional arguments and avoid further delay in the resolution of this matter. Thank you very much for your attention to this matter. We look forward to the court's favorable consideration of this request. Sincerely, [Your Name] [Your Title/Position, if applicable]
Connecticut Sample Letter for Plaintiff's Motion for Leave to File a Supplemental Memorandum
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How to fill out Connecticut Sample Letter For Plaintiff's Motion For Leave To File A Supplemental Memorandum?
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FAQ
A Motion to Compel is a formal request to the Court to require a party or a non-party in a lawsuit to comply with a discovery request such as a request for production, request for admission, interrogatory, or subpoena.
These grounds can include, but are not limited to: forum non conveniens, meaning it is more appropriate for another court to hear the case; prior pending action, meaning a case between the parties on the same matter is already happening; or in a medical malpractice case the Certificate of Good Faith not being properly ...
Deadline 45 days: Motion to Compel must be filed within 45 days from insufficient response [See Above].
Com·pel·ling. : to cause to do or occur by overwhelming pressure and esp. by authority or law [cannot the defendant to testify] [the result?
Motions for orders of compliance (or motions to compel, as they are frequently called) are governed by Section 13-14 of the Connecticut Practice Book. As in many jurisdictions, judges in Connecticut generally prefer that parties and their counsel resolve discovery disputes without the need for judicial intervention.
Ing to Connecticut Practice Book section 10-37(a), the Request to Revise shall be considered granted by the Clerk on the date it is filed. The Plaintiff has 30 days to make the requested revisions to the Complaint, unless the Plaintiff files an Objection.
A motion to sever is to have the judge order a separate trial for each co-defendant.
We don't like Motions to Compel. Judges don't like them, and neither do the opposing parties we bring them against. But they are, sometimes, required to be brought in cases where you need information to make sure you know what facts, witnesses and documents are in a case prior to going to going to trial.
