[Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] [Recipient's Name] [Recipient's Address] [City, State, ZIP] Subject: Joint Motion for Leave to Propound Additional Discovery Dear [Recipient's Name], I hope this letter finds you in good health. I am writing to you as counsel for the [Plaintiff/Defendant] in the above-mentioned case, currently pending in the [Name of Court] in [City, State]. Please accept this letter as our Joint Motion for Leave to Propound Additional Discovery. The purpose of this joint motion is to seek permission from the court to conduct additional discovery beyond the scope of what has already been permitted by the court's previous order. We believe that the proposed additional discovery is essential for the fair determination of the issues involved in this case. The details of our motion are as follows: 1. Background [Provide a brief overview of the case, including the parties involved, relevant dates, and a summary of the disputed issues.] 2. Basis for Additional Discovery [Explain why the proposed additional discovery is necessary to obtain relevant information, clarify certain facts, or to rebut opposing claims.] 3. Proposed Additional Discovery [List and describe the specific types of discovery sought, such as interrogatories, requests for production of documents, requests for admission, depositions, etc. Explain how each type of discovery will aid in establishing the facts or supporting our client's position.] 4. Relevant Legal Standard [Discuss the applicable rule or statute governing the court's authority to grant additional discovery and the factors that the court should consider in deciding the motion.] 5. Resolution Attempt [Optional: If the parties have made efforts to resolve the issues without court intervention, mention the details of such attempts.] 6. Conclusion [Restate the request for the court's permission to conduct additional discovery and express willingness to cooperate and comply with any additional orders the court may impose.] We have attached a proposed Order for the court's consideration, which grants our motion and outlines the terms and conditions under which the additional discovery should take place. We kindly request that you review this joint motion and respond to it within [timeframe, e.g., 14 days] from the date of this letter. If you have any concerns or objections, please let us know as soon as possible so that we may address them promptly. Thank you for your attention to this matter. We look forward to your response and hope that the court will grant our Joint Motion for Leave to Propound Additional Discovery. Sincerely, [Your Name] [Your Law Firm] [Law Firm Address] [City, State, ZIP] [Email Address] [Phone Number] Attachments: — Proposed Order on Joint Motion for Leave to Propound Additional Discovery