[Your Name] [Your Address] [City, State, ZIP Code] [Email Address] [Phone Number] [Date] [Recipient's Name] [Recipient's Position] [Courthouse Name] [Courthouse Address] [City, State, ZIP Code] Re: Joint Motion for Leave to Propound Additional Discovery Case: [Case Name and Number] Dear [Clerk's Name], I hope this letter finds you in good health. I am writing to submit a Joint Motion for Leave to Propound Additional Discovery in the above-mentioned case. As part of our ongoing efforts to gather vital information, we are seeking the permission of the court to conduct additional discovery. New Hampshire law allows parties to request additional discovery if there are legitimate reasons to believe that relevant evidence may exist beyond what has already been provided or discovered. We firmly believe that this is the case here and thus submit this joint motion to acquire the court's authorization. Our joint motion for leave to propound additional discovery includes the following key elements: 1. Background: Provide a brief overview of the case, stating the parties involved and the nature of the legal dispute. Explain the necessity of conducting additional discovery to ensure a fair and just resolution. 2. Purpose: Clearly state the purpose of the additional discovery sought. Specify the type(s) of evidence or information we intend to uncover through this process. Examples of additional discovery may include interrogatories, requests for production of documents, depositions, or other forms of inquiry. 3. Relevance: Outline the specific reasons why we believe the requested additional discovery is relevant to the case. Additionally, demonstrate how the information sought has the potential to shed light on crucial aspects, advance our understanding of the matter, and ultimately serve the interests of justice. 4. Legal Grounds: Cite the relevant New Hampshire statutes, court rules, or case precedents that support our motion for leave to propound additional discovery. Provide detailed explanations and argumentation as to why the court should grant our request based on the legal principles and standards applicable in New Hampshire. 5. Proposed Timeline: Suggest a realistic timeline for conducting the proposed additional discovery. This timeline should adequately allow all parties to prepare and respond while considering any applicable deadlines or constraints imposed by the court. We kindly ask you to file this Joint Motion for Leave to Propound Additional Discovery with the court and provide a filed-stamped copy to all parties involved. Enclosed with this letter are the necessary copies of the motion, along with proof of service to the opposing party. We appreciate your attention to this matter and value the court's assistance in ensuring a fair and judicious resolution of this case. Should you have any questions or require further information, please do not hesitate to contact me at [Your Phone Number] or via email at [Your Email Address]. Thank you for your prompt attention to this request. We look forward to receiving confirmation of the motion's filing and the court's ruling on our Joint Motion for Leave to Propound Additional Discovery. Sincerely, [Your Name] [Your Title/Position] [Your Organization, if applicable]
New Hampshire Sample Letter to Clerk for filing Joint Motion for Leave to Propound Additional Discovery
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Upon a sufficient showing of good cause, the court may at any time order that discovery required hereunder be denied, restricted, or deferred, or make such other order as is appropriate.
Medical Injuries and Special Damages. (a) Medical Examinations. In actions to recover damages for personal injuries, the defendant shall have the right to a medical examination of the plaintiff prior to trial.
(i) The party, who is served with interrogatories, shall serve his or her answers thereto, by mail or delivery in hand, upon the party propounding them within 30 days after service of such interrogatories.
Summary Disposition. (1) Except in a mandatory appeal, the supreme court may at any time, on its own motion and without notice or on such notice as it may order, dispose of a case, or any question raised therein, summarily.
Depositions. (a) A party may take as many depositions as necessary to adequately prepare a case for trial so long as the combined total of deposition hours does not exceed 20 unless otherwise stipulated by counsel or ordered by the court for good cause shown.
Rule 9. Answers; Defenses; Forms of Denials. (a) An Answer or other responsive pleading shall be filed with the court within 30 days after the person filing said pleading has been served with the pleading to which the Answer or response is made.
Trial Procedure. (1) Opening Statements. Opening statements are not permitted in circuit court ? district division trials except with permission of the court for good cause shown.
(A) Deposition of an Expert Who May Testify. A party may depose any person who has been identified as an expert whose opinions may be presented at trial. If Rule 26(a)(2)(B) requires a report from the expert, the deposition may be conducted only after the report is provided.
