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]