Iowa Sample Letter conveying Joint Motion for Leave to Propound Additional Discovery

State:
Multi-State
Control #:
US-0092LTR
Format:
Word; 
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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] [Recipient's Name] [Recipient's Address] [City, State, Zip Code] Re: Joint Motion for Leave to Propound Additional Discovery Dear [Recipient's Name], I hope this letter finds you well. I am writing on behalf of my client, [Your Client's Name], in relation to the pending legal matter concerning [Provide a brief description of the case]. As parties involved in this litigation, we hereby jointly submit this Motion for Leave to Propound Additional Discovery, pursuant to the applicable rules of the Iowa Rules of Civil Procedure. As you may be aware, our previously exchanged discovery requests and responses have provided valuable information related to the case. However, after careful review and consideration of the new information that has recently come to our attention, we believe it is crucial to pursue further discovery in order to fully ascertain the facts and adequately prepare for trial. In light of the foregoing, we kindly request leave of the court to propound additional discovery requests to the opposing party, [Opposing Party's Name]. The proposed additional discovery seeks to obtain crucial documents and information that would aid in the determination of liability, damages, and other relevant issues in this case. We firmly believe that the proposed discovery is necessary and bears significant relevance to the underlying claims and defenses. To assist the court in evaluating our joint motion, we have attached a proposed schedule outlining the dates for serving the additional discovery requests, the deadline for responses, and any necessary hearings or conferences. We are open to modifications and adjustments to this proposed schedule to accommodate the court's availability and any concerns raised by the opposing party. Through this joint motion, we demonstrate our commitment to a fair and efficient resolution of this matter. We have engaged in good faith negotiations and are confident that granting this motion will be instrumental in resolving the issues effectively and fairly. By allowing us the opportunity to obtain further discovery, we are confident that both parties will benefit from a more informed and comprehensive presentation of our respective positions. We kindly ask for your prompt attention and consideration of this motion. Please do not hesitate to reach out to me if you require any additional information or have any concerns regarding this matter. Thank you for your attention to this important request. We look forward to your favorable response and the court's guidance on the matter. Yours sincerely, [Your Name] [Your Designation/Title] [Law Firm Name (if applicable)] [Phone Number] [Email Address] Enclosures: 1. Proposed Schedule for Additional Discovery Requests.

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FAQ

Under Iowa Rule of Civil Procedure 1.981(3), summary judgment is appropriate only when no genuine issue of material fact exists and the moving party is entitled to a judgment as a matter of law.

A Motion to Compel asks the judge to order the opposing party to answer the discovery inquiry more fully or appropriately. If the judge grants the motion the opposing party may be required to pay the attorney fees associated with the delay due to the objections.

In addition, rule 1.943 allows for voluntary dismissal of the plaintiff's petition without prejudice once as a matter of right. Id. r. 1.943.

Rule 1.910 - Motions for continuance 1. 910(1) Motions for continuance shall be filed without delay after the grounds therefor become known to the party or the party's counsel. Such motion may be amended only to correct a clerical error.

An attorney can issue a subpoena without a court file being opened, but if the clerk issues a blank subpoena, a court file must be opened and will collect a $50 fee. Rule 1.1702(5). A court file will also be opened for any motions relating to the subpoena and the clerk will collect a $50 fee then as well.

Some examples that your lawyer may request as part of their motion for discovery are: Photos or videos of the crime scene. Witness statements. Police reports or notes. Lab tests and reports. Alibi witness statements.

944(1) It is the declared policy that in the exercise of reasonable diligence every civil and special action, except under unusual circumstances, shall be brought to issue and tried within one year from the date it is filed and docketed and in most instances within a shorter time.

In addition to proceedings encompassed by rule 1.904(1), a rule 1.904(2) motion to reconsider, enlarge, or amend another court order, ruling, judgment, or decree will be considered timely if filed within 15 days after the filing of the order, judgment, or decree to which it is directed.

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Iowa Sample Letter conveying Joint Motion for Leave to Propound Additional Discovery