Subject: Joint Motion of Entry of Second Amended Scheduling Order in the State of New Mexico [Your Name] [Address] [City, State, Zip Code] [Email Address] [Phone Number] [Date] [Judge's Name] [Judge's Designation] [New Mexico District Court] [Address] [City, State, Zip Code] RE: Joint Motion of Entry of Second Amended Scheduling Order Case No: [Case Number] Plaintiff: [Plaintiff's Name] Defendant: [Defendant's Name] Dear Honorable [Judge's Last Name], We, the undersigned parties to the above-mentioned case, submit this joint motion for the entry of a Second Amended Scheduling Order. In light of recent developments, we believe that modifying the existing scheduling order is necessary to ensure fair and efficient proceedings. 1. Background: Provide a concise background of the case, including any pertinent dates, events, or key legal issues. 2. Reason for Amendment: Explain the compelling reasons for seeking an amendment to the existing scheduling order. It may include new evidence, discovery disputes, changes in parties, unforeseen circumstances, or any other relevant factors. 3. Proposed Amended Schedule: Present a detailed outline of the proposed amendments, clearly stating the modifications for each phase of the litigation process, including: a. Discovery: Specify any alterations to the discovery timeline, crucial deadlines, and the inclusion of any new or additional discovery requests. b. Pretrial Proceedings: Provide any necessary adjustments to pretrial procedures, including the exchange of witness lists, expert reports, exhibit lists, stipulations, or dispositive motion deadlines. c. Trial: Mention any changes related to the trial date, proposed length, jury selection, pretrial conferences, and any other relevant trial preparations. d. Additional Matters: Address any ancillary matters that require consideration, such as alternative dispute resolution, settlement conferences, or any other relevant proceedings. 4. Agreement of Parties: State that all parties involved agree to these proposed amendments and have signed this joint motion. 5. Proposed Order: Attach a clean copy of the proposed Second Amended Scheduling Order for the court's convenience. 6. Conclusion: Express gratitude for the court's attention to this motion and request that it be granted on behalf of all parties involved to preserve the fairness and efficiency of the litigation process. We kindly request a prompt review and favorable consideration of this joint motion for the entry of the Second Amended Scheduling Order. Thank you for your attention to this matter. Respectfully submitted, [Plaintiff's Attorney Name] [Law Firm Name] [Address] [City, State, Zip Code] [Email Address] [Phone Number] [Defendant's Attorney Name] [Law Firm Name] [Address] [City, State, Zip Code] [Email Address] [Phone Number] [Signature lines for all parties] Types of New Mexico Sample Letters for Joint Motion of Entry of Amended Scheduling Order: 1. Sample Letter for Joint Motion of Entry of First Amended Scheduling Order 2. Sample Letter for Joint Motion of Entry of Third Amended Scheduling Order 3. Sample Letter for Joint Motion of Entry of Modified Scheduling Order Note: The specific amended scheduling order names will depend on the applicable case and the number of amendments submitted.
New Mexico Sample Letter for Joint Motion of Entry of Second Amended Scheduling Order
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How to fill out New Mexico Sample Letter For Joint Motion Of Entry Of Second Amended Scheduling Order?
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"Filing" shall include filing a facsimile copy or filing an electronic copy as may be permitted under Rule 1-005.1 NMRA or Rule 1-005.2 NMRA. If a party has filed a paper using electronic or facsimile transmission, that party shall not subsequently submit a duplicate paper copy to the court.
Any document required to be served by Paragraph A of Rule 1-005 NMRA may be served on a party or attorney by facsimile transmission if the party or attorney has: (1) listed a facsimile telephone number on a pleading or paper filed with the court in the action; (2) a letterhead with a facsimile telephone number; or (3) ...
Rule 1-011 - Signing of pleadings, motions, and other papers; sanctions; unsworn affirmations under penalty of perjury A. Signing of pleadings, motions, and other papers; sanctions.
Rule 1-015 NMRA permits the voluntary dismissal of individual claims that make up an action.
Written order. Whenever counsel undertakes to represent a defendant in any criminal action, he will file a written entry of appearance in the cause, unless he has been appointed by written order of the court. For the purpose of this rule, the filing of any pleading signed by counsel constitutes an entry of appearance.
Rule 1-004(F)(3) provides that service may be made by delivering a copy of the summons and complaint to the person apparently in charge of the actual place of business of the defendant and mailing a copy of the summons and complaint to the defendant both at the defendant's last known mailing address and also the ...
Filing Motions A motion must be in writing and must specifically state the grounds for the motion and the relief sought. The party filing the motion (the ?movant?) must request concurrence of each party at least three working days before filing the motion.
Rule 1-007.1 - Motions; how presented A. Requirement of written motion. All motions, except motions made during trial, or as may be permitted by the court, shall be in writing and shall state with particularity the grounds and the relief sought.
