[Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] [Judge's Name] [Judge's Designation] [Court Name] [Court Address] [City, State, ZIP] Re: Case No. [Case Number] [Plaintiff's Name] v. [Defendant's Name] Dear Honorable [Judge's Name], We, the undersigned counsel for the parties involved in the above-mentioned case, jointly submit this Motion for Leave to Propound Additional Discovery, in accordance with the rules and procedures governing the Maryland Court. I. Introduction: This Motion seeks the Court's permission to propound additional discovery, beyond the case's initial request for information, in order to investigate and gather essential evidence that would significantly aid in the determination of the issues at hand. II. Background: Provide a brief summary of the case, including relevant parties' involvement, legal claims, and any significant milestones or developments. III. Legal Basis: Explain the legal basis for the requested additional discovery, referencing relevant Maryland rules and statutes that govern discovery procedures, such as the Maryland Rules of Civil Procedure. IV. Justification for Additional Discovery: Clearly articulate the reasons why the additional discovery is necessary for a fair and just resolution of the case, along with its potential impact on the outcome. Use specific examples, if applicable, to underscore the crucial information sought and how it directly relates to the disputed issues. V. Scope and Nature of Additional Discovery: Specify the nature, extent, and specific categories of discovery requested, such as written interrogatories, requests for production of documents, requests for admission, or depositions. Emphasize that the requested discovery is both proportional to the needs of the case and reasonable in scope, aiming to strike a balance between the parties' substantive rights and the efficient administration of justice. VI. No Undue Burden or Delay: Affirm that the requested additional discovery will not cause undue burden or delay to either party. Assure the Court that both parties have agreed to cooperate and expedite the discovery process, ensuring that the interests of justice are upheld. VII. Conclusion: Counsel respectfully request that the Court grant this Joint Motion for Leave to Propound Additional Discovery, allowing the undersigned parties the opportunity to conduct necessary investigations and obtain crucial evidence, thereby promoting the fair and equitable resolution of this case. Thank you for considering this Motion. We remain at the Court's disposal for any further information or clarification required regarding this request. Sincerely, [Your Name] [Your Law Firm Name] [Your Law Firm Address] [City, State, ZIP] [Email Address] [Phone Number] Copy to: [Opposing Counsel Name] [Opposing Counsel Law Firm Name] [Opposing Counsel Law Firm Address] [City, State, ZIP]
Maryland Sample Letter conveying Joint Motion for Leave to Propound Additional Discovery
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How to fill out Sample Letter Conveying Joint Motion For Leave To Propound Additional Discovery?
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FAQ
Discovery means you send the other side questions and requests for information or items (like documents) in writing. The other side must respond to your question or request in writing.
Instead, the party generating the discovery material shall serve the discovery material on all other parties and promptly shall file with the court a notice stating (A) the type of discovery material served, (B) the date and manner of service, and (C) the party or person served.
This letter is often called a good faith letter. And it is needed under many courts' rules before you can file a motion to compel discovery if the other party ignores your requests or provides evasive responses or move for sanctions if your opponent refuses to comply with the court's discovery order.
A deposition is a meeting where oral questions are asked, while an interrogatory is a written series of questions. During the discovery process, parties are required to produce evidence and provide information about their case. During a deposition, one party asks the other questions and records their responses.
If you object to a discovery request, generally you have to let the other side know that you are not giving him/her documents that s/he has asked for.
Failure of United States to Participate in Good Faith in Discovery. Rule 37 authorizes the court to direct that parties or attorneys who fail to participate in good faith in the discovery process pay the expenses, including attorney's fees, incurred by other parties as a result of that failure.
Good faith is a legal term that describes the intention of the party or parties in a contract to deal in an honest manner with each other. In contracts, the parties signing abide by and uphold the contract. It requires people to act honestly without taking advantage of others.
You may object to a discovery request if you have a reason. For example, if the request is not relevant to the case, you may object stating the request is irrelevant. Other common objections include that the request is too vague or too burdensome. Be careful when making objections.
