[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.