Sample Letter for Drafts of a Joint Motion for Additional Discovery and an Order Approving Same: Delaware Edition Dear [Recipient's Name], I am writing to you on behalf of [Your Client's Name], in reference to the ongoing litigation matter [Case Name and Number] pending in the Delaware Court. Pursuant to the Delaware Court Rules [provide Rule number if applicable], we kindly request your assistance in drafting a joint motion for additional discovery and an order approving the same. As you are aware, the discovery phase of litigation plays a crucial role in ensuring a fair and just resolution. It allows both parties to gather relevant evidence, testimonies, and information essential to presenting their case effectively. However, circumstances may arise during the litigation process that necessitate the need for additional discovery to ensure a comprehensive understanding of the matter at hand. Our client firmly believes that further discovery is crucial to fully investigate and address certain aspects of this case. Thus, we propose the submission of a joint motion for additional discovery, indicating the grounds for such request and outlining the specific areas our client intends to explore. This collaborative approach allows both parties to avoid unnecessary disputes and promotes a more efficient resolution of the case. In preparing the joint motion, we kindly request that you consider incorporating the following elements: 1. Introduction: Clearly state the purpose and significance of the joint motion, providing a brief summary of the case and its current status. 2. Background: Outline the key factual background of the case, highlighting any areas where additional discovery is deemed necessary. 3. Legal Basis: Cite relevant Delaware Court Rules and any supporting case law that demonstrate the appropriateness of seeking additional discovery in this matter. 4. Scope of Additional Discovery: Specify the exact areas, subjects, or documents that our client wishes to explore through the additional discovery process. 5. Justification: Clearly articulate the reasons why the proposed additional discovery is crucial to advancing our client's interest in the litigation. Emphasize how the additional information sought will contribute to a more comprehensible presentation of the case. 6. Cooperation: Express our client's willingness to cooperate fully with the opposing party, including the provision of reciprocal discovery, reasonable timelines, and any other necessary terms to facilitate an efficient and fair process. 7. Proposed Order: Attach a draft order for the court's consideration that approves the joint motion for additional discovery, with any necessary modifications to ensure compliance with the Delaware Court's rules and procedures. We believe that by submitting a joint motion, we can streamline the process while maintaining transparency and fostering cooperation. We are confident that the Delaware Court will recognize the relevance and merits of our request, allowing for a fair and thorough examination of the case. Please review this letter, and if you agree with the proposed approach, kindly proceed with the drafting of the joint motion and accompanying order for our further review and eventual filing with the court. We value your legal expertise and appreciated your assistance in preparing these essential documents. Thank you for your prompt attention to this matter. We look forward to working collaboratively and strategically towards a successful outcome. Sincerely, [Your Name] [Your Law Firm's Name] [Contact Information]