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New York Sample Letter to Clerk for filing Joint Motion for Leave to Propound Additional Discovery

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This form is a sample letter in Word format covering the subject matter of the title of the form.

Subject: New York Sample Letter to Clerk for Filing Joint Motion for Leave to Propound Additional Discovery — Comprehensive Guide Dear Clerk, I hope this letter finds you well. Today, I am writing to provide you with a detailed description and step-by-step instructions for filing a Joint Motion for Leave to Propound Additional Discovery in the state of New York. This document intends to serve as a sample letter to assist you in navigating the process smoothly and effectively. Please note that variations of this motion may exist depending on your specific requirements and circumstances, but the provided guidelines should generally apply. 1. Title and Heading: Begin the document with the court's name, case caption, and index number at the top of the page to ensure clarity and proper identification. 2. Introduction: Address the letter to the appropriate Clerk or Judge and briefly introduce the purpose of the motion, which is to request consent for additional discovery in the ongoing case. Clearly state that it is a joint motion, highlighting that all parties involved are in agreement. 3. Background Information: Provide a concise summary of the background details of the case. Mention the relevant parties' names, key dates, and any other important information that will assist the Clerk or Judge in understanding the context in which the motion is being filed. 4. Legal Basis: Include a section that outlines the legal basis supporting the request for additional discovery. Reference applicable statutes, rules of procedure, and case law that justify the need for the extra investigation. It is crucial to demonstrate that this motion follows proper legal principles and is necessary for a fair and just resolution of the dispute. 5. Explanation of Additional Discovery: Elaborate on the specific type of discovery being sought. This might include interrogatories, document requests, subpoenas, depositions, or other relevant methods. Clearly identify the proposed questions or categories of information to be pursued during the discovery process. 6. Timelines and Deadlines: Specify a reasonable timeline for conducting the additional discovery. State the desired completion date for the discovery phase and the proposed due date for all responses from the opposing party. Indicate that these deadlines align with the court's schedule and allow ample time for both parties to adequately prepare and respond. 7. Cooperation and Consent: Emphasize that all parties involved have discussed the matter and are in agreement to pursue additional discovery in an effort to promote transparency, fairness, and the just resolution of the case. Make it clear that this joint motion is submitted with the mutual consent of all parties involved. 8. Certification and Signatures: Include a certification section at the end of the document where all parties, including their respective attorneys, can sign to attest to the accuracy and authenticity of the motion. Provide space for dates and contact information, ensuring every individual's identity is clearly stated. Remember, this is a sample letter meant to serve as a starting point for drafting your motion for leave to propound additional discovery. It is advisable to consult an attorney familiar with the specific details of your case to ensure compliance with the applicable laws and rules, as well as any additional requirements unique to your jurisdiction. I believe the guidelines provided in this letter will help you in successfully filing a Joint Motion for Leave to Propound Additional Discovery in New York. If you have any further questions or require additional assistance, please do not hesitate to contact me. Thank you for your attention and cooperation. Sincerely, [Your Name] [Your Title/Position] [Your Contact Information]

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FAQ

Specifically, pursuant to Uniform Rule 202.7 (f), upon an application for an order to show cause that seeks a temporary restraining order, the application must contain an affirmation demonstrating that there will be significant prejudice to the party seeking the restraining order by the giving of notice.

22 CRR-NY 202.8-CRR (1) affidavits, affirmations, briefs and memoranda of law in chief shall be limited to 7,000 words each; (2) reply affidavits, affirmations, and memoranda shall be no more than 4,200 words and shall not contain any arguments that do not respond or relate to those made in the memoranda in chief.

Stay of Discovery. In Part 49: The making of a motion pursuant to CPLR 3211 or 3212 shall not stay the production of documents. CPLR 3214(b). While these types of motions are pending, all other discovery requests will be handled on a case-by-case basis.

Within 20 days after service of a note of issue and certificate of readiness, any party to the action or special proceeding may move to vacate the note of issue, upon affidavit showing in what respects the case is not ready for trial, and the court may vacate the note of issue if it appears that a material fact in the ...

11-f - Depositions of Entities; Identification of Matters (a) A notice or subpoena may name as a deponent a corporation, business trust, estate, trust, partnership, limited liability company, association, joint venture, public corporation, government, or govern- mental subdivision, agency or instrumentality, or any ...

Section 202.8-g - Motions for Summary Judgment; Statements of Material Facts (a) Upon any motion for summary judgment, other than a motion made pursuant to CPLR 3213, the court may direct that there shall be annexed to the notice of motion a separate, short and concise statement, in numbered paragraphs, of the material ...

Interrogatories shall be answered in writing under oath by the party served, if an individual, or, if the party served is a corporation, a partnership or a sole proprietorship, by an officer, director, member, agent or employee having the information.

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Court staff can provide all litigants with procedural information. Summons, Complaint and Answers, PDF. Civil Supreme Flowchart, PDF. How To Commence A Civil ... Motions made by notice of motion and petitions and notices of petition in special proceedings are processed by the General Clerk's Office (Room 119) and are ...Oct 26, 2021 — To request a pre-motion conference, the moving party shall serve on all other parties and electronically file a letter not to exceed three. May 18, 2021 — Parties wishing to file a document under seal must submit the request on ECF as a “Motion for Leave to Electronically File Document Under. First and foremost, carefully verify if the Suffolk Sample Letter to Clerk for filing Joint Motion for Leave to Propound Additional Discovery is tailored to ... (a) Signature. Every pleading, written motion, and other paper must be signed by at least one attorney of record in the attorney's name—or by a party ... This is an informational handbook. This handbook is a guide for self-represented litigants. It is not legal advice and should not be considered as such. Jul 1, 2023 — ... leave to file the cross-petition if it is filed not later than ten days after the filing of the original answer. Otherwise leave may be obtained. (B) Prior to filing a motion seeking resolution of a discovery ... This would include the GAL's right to file appropriate discovery requests and request the. CHAPTER 10: TAKING ACTION AGAINST AN UNPAID JUDGMENT. Lien on Real Property (Starting the Process on Lien). (Lien on Debtor's business assets).

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New York Sample Letter to Clerk for filing Joint Motion for Leave to Propound Additional Discovery