Hawaii Sample Letter to Clerk for filing Joint Motion for Leave to Propound Additional Discovery

• Category: Letters - Legal - Motions
• State: Multi-State
• Control #: US-0863LTR
• 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 Code] [Email Address] [Phone Number] [Date] [Full Name of the Clerk] [Court Name] [Address] [City, State, ZIP Code] Subject: Joint Motion for Leave to Propound Additional Discovery in the Case of [Case Name and Number] Dear [Clerk's Last Name], I am writing to you today on behalf of the parties involved in the above-mentioned case to file a Joint Motion for Leave to Propound Additional Discovery. We kindly request your assistance in processing this motion and scheduling a hearing for its consideration. [Explain the purpose and background of the letter:] In order to adequately prepare for trial and ensure fair and just proceedings, it has become necessary for both parties to seek permission from the court to conduct additional discovery beyond what has already been permitted. [Provide a summary of the discovery sought:] The additional discovery specifically includes but is not limited to the following: 1. Interrogatories — We seek permission to submit additional sets of interrogatories to gain further insight into the opposing party's claims, defenses, and relevant information. 2. Requests for Production of Documents — We request authorization to submit new and specific requests for the production of documents that we believe are crucial to understanding the case and presenting our respective arguments. 3. Requests for Admissions — We require the opportunity to pose additional requests for admissions to clarify certain facts and issues, which will aid in streamlining the proceedings and help avoid unnecessary disputes. 4. Depositions — We propose conducting additional depositions of specific witnesses who possess information crucial to the case and whose testimony will be of material importance during trial. [Clarify the reasons for seeking additional discovery:] The need for additional discovery arises from the following reasons: 1. Complexity of the Case — The complexity of the legal and factual issues within this case warrants further exploration to prevent any possible prejudice and ensure a fair trial. 2. New Evidence — Recently discovered evidence, which was not available during the initial discovery phase, has significantly altered the landscape of this case, necessitating further investigation. 3. Witness Testimony — Additional depositions and interrogatories will allow for a thorough examination of vital witnesses whose testimony can greatly impact the outcome of this litigation. 4. Substantial Interests Involved — The particular importance of the matters at stake in this case merits the authorization of additional discovery to establish a complete and accurate record. [Include a statement of cooperation:] Please note that both parties are in agreement regarding this motion and have cooperatively worked towards its preparation. We believe that the proposed additional discovery is essential to ensure a fair and just resolution of this matter. [Provide the proposed schedule and requested hearing date:] We kindly request a hearing be scheduled at the earliest convenience of the court. Please consider the following proposed schedule: — Deadline to respond to this motion: [Insert Date] — Proposed hearing date: [Insert Date and Time] [Conclude the letter with a polite closing:] We appreciate the diligent work of the court in this matter and kindly request your prompt attention to this motion. Please let us know if there are any additional requirements or information needed to successfully process this joint motion. Thank you for your attention to this matter. Sincerely, [Your Name] Enclosures: [List any attachments]