[Your Name] [Your Address] [City, State, ZIP Code] [Email Address] [Phone Number] [Date] [Judge's Name] [Judge's Designation] [Name of the Court] [Court's Address] [City, State, ZIP Code] Re: Plaintiff's Motion for Leave to File a Supplemental Memorandum Case Name: [Your Case Name] Case Number: [Case Number] Dear Honorable [Judge's Last Name], I am writing to respectfully request the court's permission to file a supplemental memorandum on behalf of the plaintiff in the above-mentioned case. This motion is made under Rule [provide specific rule number] of the New York [mention the appropriate court] Rules [civil or appellate] and is based on the following grounds: 1. Change in Circumstances: There have been significant changes in circumstances since the submission of the original memorandum, which necessitate clarification and additional supporting arguments. 2. Recent Legal Developments: Several relevant legal developments, including recent court decisions and legislative changes, have occurred after the filing of the original memorandum. It is crucial to present these legal precedents to the court for a comprehensive and up-to-date analysis of the issues at hand. 3. Additional Evidence: New evidence, discovered after the filing of the original memorandum, has come to light. This evidence is material to the plaintiff's claims and would substantially enhance the court's understanding of the case. 4. Response to Counterarguments: The defendant's responsive memorandum has raised new factual or legal arguments that warrant a direct response from the plaintiff. It is essential to address these arguments to ensure a fair and impartial consideration by the court. In light of the above circumstances, the plaintiff respectfully requests the following relief: 1. Permission to File a Supplemental Memorandum: Granting leave to file a supplemental memorandum, allowing the plaintiff to make additional arguments, clarify existing points, and address newly raised contentions. 2. Extended Deadline: If the court deems it necessary, the plaintiff requests an extension of the deadline to file the supplemental memorandum. This extension will allow ample time to adequately address the new issues and submit a comprehensive document. Enclosed with this letter, please find a copy of the proposed supplemental memorandum for the court's review. The plaintiff assures the court that the supplemental memorandum will not unduly delay the proceedings or cause prejudice to the defendant. It is solely intended to assist the court in arriving at a just and equitable resolution of the case. Thank you for considering this motion. The plaintiff respectfully requests that the court grant leave to file a supplemental memorandum and provide any necessary extensions to the deadline. If the court requires any further information or documentation, please do not hesitate to contact the undersigned. Respectfully yours, [Your Name]