[Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] Clerk of Court [Courthouse Address] [City, State, ZIP] Re: Joint Motion for Leave to Propound Additional Discovery Case No: [Case Number] Dear Clerk of Court, I am writing to file a Joint Motion for Leave to Propound Additional Discovery in the above-mentioned case. Please find enclosed the necessary documents and related information to facilitate the filing. As per the North Dakota Rules of Civil Procedure, Rule 26, we respectfully request permission from the court to initiate the process of additional discovery. The purpose of this joint motion is to obtain an extension of the discovery period and expand the scope of discovery in order to gather crucial evidence to support our respective clients' positions. The parties involved, namely [Plaintiff's Name] and [Defendant's Name], have reached an agreement on the need for additional discovery to facilitate a fair and just resolution of this case. This motion is jointly submitted and supported by both parties, signifying our mutual commitment to comply with the discovery process and uncover all relevant facts related to this lawsuit. To ensure a comprehensive and efficient discovery process, we respectfully request the court's permission to take the following additional steps: 1. Interrogatories: Allow the parties to pose written questions to one another, seeking specific information, documents, or admissions that may be relevant to the case. The requested extension will enable us to serve and respond to additional interrogatories within the designated time frame. 2. Requests for Production: Allow the parties to request the production of documents, electronically stored information (ESI), or other tangible items relevant to the dispute. Granting this motion would allow us to serve and respond to additional requests for production during the extended discovery period. 3. Depositions: Permit the parties to conduct additional depositions of witnesses, experts, or any other individuals with information that may be material to the case. The joint motion seeks to extend the deadline for conducting depositions to ensure a thorough examination of all relevant parties. 4. Expert Witnesses: Allow the parties to disclose additional expert witnesses and exchange reports within an extended timeline. This will provide an opportunity to present expert testimony crucial to the understanding and resolution of complex issues involved in this case. 5. Any other relevant discovery methods or actions that the court deems necessary for a fair and just resolution of this matter. We assure the court that this motion is not intended to cause any unnecessary delay or burden in this litigation process. Instead, it serves as a means to complete discovery effectively, ensuring the parties have access to the necessary evidence to present their respective cases fully. Thank you for your attention to this matter. Should you require any additional information or documentation, please do not hesitate to contact me at [Phone Number] or via email at [Email Address]. Sincerely, [Your Name] [Your Attorney's Name, if applicable] [Your Bar Number, if applicable]
North Dakota Sample Letter to Clerk for filing Joint Motion for Leave to Propound Additional Discovery
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How to fill out North Dakota Sample Letter To Clerk For Filing 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.
Here are some of the things lawyers often ask for in discovery: anything a witness or party saw, heard, or did in connection with the dispute. anything anyone said at a particular time and place (for example, in a business meeting related to the dispute or after a car accident that turned into a lawsuit)
Discovery is the formal process by which the parties to a case in court exchange information about the case. This includes information about the witnesses and evidence to be presented at trial. Its purpose is to make the parties aware of the evidence which may be presented at trial.
How to use Special Interrogatories Download a template for Special Interrogatories. There are many different templates available for Special Interrogatories. ... Fill out basic information at the top. ... Add your own definitions (if useful) ... Write your questions (interrogatories) ... Sign and date the document. ... Make copies.
Unless otherwise limited by court order, the scope of discovery is as follows: Parties may obtain discovery regarding any nonprivileged matter that is relevant to any party's claim or defense, including the existence, description, nature, custody, condition, and location of any documents, electronically stored ...
Discovery is how you gather the evidence you will need to prove your case as plaintiff, or defeat the plaintiff's case as a defendant. You use discovery to find out things like: What the other side plans to say about an issue in your case. What facts or witnesses support their side.
(1) Sanctions by Court in District Where Deposition Is Taken. If a deponent fails to be sworn or to answer a question after being directed to do so by the court in the judicial district in which the deposition is being taken, the failure may be considered a contempt of that court.
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.
