Title: New York Sample Letter for Joint Motion of Entry of Second Amended Scheduling Order Introduction: In the realm of legal proceedings, a joint motion of entry is filed to request the approval of a court order that outlines a revised schedule for the case. This article aims to provide a detailed description and guidance on drafting a New York Sample Letter for Joint Motion of Entry of Second Amended Scheduling Order. The suggested content below highlights essential components and relevant keywords to ensure the letter's effectiveness. Content: 1. Heading: — Use court-accepted format (e.g., Supreme Court of the State of New York). — Mention both parties involved in the case. — Highlight that it is a joint motion. Example: SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF [County Name] Plaintiff's Name, Plaintiff, againstns— - Defendant's Name, Defendant. JOINT MOTION OF ENTRY OF SECOND AMENDED SCHEDULING ORDER 2. Introduction: — Identify the current scheduling order (e.g., First Amended Scheduling Order). — Explain the purpose of the joint motion (to request changes). Example: Dear [Judge's Full Name]: We, the plaintiffs and defendants in the aforementioned case, jointly submit this letter as a motion for the entry of the Second Amended Scheduling Order. The purpose of this joint motion is to seek necessary amendments to the current schedule previously established under the First Amended Scheduling Order. 3. Background Information: — Provide an overview of the case's history. — Explain the reasons necessitating the amendment. — Mention all relevant parties' agreement on the proposed amendments. Example: As Your Honor is well aware, this case involves [briefly describe the nature of the case]. Since the issuance of the First Amended Scheduling Order on [date], certain circumstances have come to light necessitating its amendment. We affirm that all parties involved consent to the proposed changes outlined in this joint motion. 4. Request for Amended Scheduling Order: — Specify the requested changes to the existing scheduling order. — Explain the reasons behind each proposed amendment (e.g., additional evidence, expert witness availability, etc.). — Suggest a revised timeline for various stages in the litigation process. Example: Based on our assessment of the case's progression and in the interest of achieving justice, we respectfully request the following amendments in the Second Amended Scheduling Order: — Modification 1: Extend the deadline for discovery by [number of days/weeks] to [new date], due to the recent disclosure of crucial evidence. — Modification 2: Extend the expert witness disclosure deadline by [number of days/weeks] to [new date], accounting for the unavailability of a key expert witness until [the expert witness's availability date]. 5. Confirmation of Agreement: — Express that all parties involved agree on the proposed changes. — Highlight the absence of objections or conflicts regarding the amended scheduling order. Example: The plaintiffs and defendants both confirm their mutual consent to the proposed amendments stated above. No objections or disputes have arisen in discussions regarding the revised timeline, underscoring the shared intention to promote fairness and efficiency during this legal process. 6. Conclusion: — Express gratitude for the court's consideration of the request. — Offer contact information for any necessary clarifications or further instructions. Example: We would like to express our sincere appreciation to Your Honor for considering this joint motion. We believe that these requested modifications to the existing scheduling order will facilitate a just and orderly resolution of this case. Should any additional information or clarifications be required, kindly contact the undersigned representatives for each party or our respective attorneys. Thank you for your attention to this matter. Yours sincerely, [Your Name] [Your Title/Position] [Plaintiff's Contact Information] [Co-Plaintiff's Name] [Co-Plaintiff's Title/Position] [Co-Plaintiff's Contact Information] [Defendant's Name] [Defendant's Title/Position] [Defendant's Contact Information] [Co-Defendant's Name] [Co-Defendant's Title/Position] [Co-Defendant's Contact Information] ------ Note: The letter above is a general template for a New York Sample Letter for Joint Motion of Entry of Second Amended Scheduling Order. It should be modified and customized according to the specific facts and circumstances of the case. Remember to consult with legal professionals for precise guidance tailored to your situation.