[Your Name] [Your Address] [City, State, ZIP Code] [Email Address] [Phone Number] [Date] [Recipient's Name] [Recipient's Address] [City, State, ZIP Code] Re: Joint Motion for Leave to Propound Additional Discovery — [Case Name and Number] Dear [Recipient's Name], I hope this letter finds you in good health. I am writing on behalf of both parties involved in the aforementioned case to submit a joint motion for leave to propound additional discovery in accordance with the rules and guidelines set forth by the Pennsylvania court system. As you are well aware, the discovery phase is an essential component of any legal proceeding. It allows both parties to gather relevant information, evidence, and testimony to be presented during the trial. Recognizing the significance of this stage, we hereby jointly request leave from the court to expand our discovery efforts beyond the scope originally outlined. This motion is necessitated by the recent developments in the case, which have brought to light new evidence and potential witnesses that could significantly impact the outcome. By expanding the discovery process, we aim to thoroughly investigate these leads to ensure a fair and just trial. Outlined below are the key details and reasons supporting our joint motion for leave to propound additional discovery: 1. Description of Additional Discovery: — Our proposed additional discovery encompasses conducting depositions, issuing interrogatories, requesting documents, and seeking expert opinions related to the newly discovered evidence and potential witnesses. — We believe that this expanded scope of discovery is necessary to fully uncover the truth and ensure that all parties have equal access to relevant information. 2. Relevance and Importance: — The new evidence and potential witnesses have the potential to substantially impact the outcome of the case. — The evidence may be crucial in corroborating existing claims or presenting novel perspectives. 3. Timeliness and Efficiency: — We assure the court that the proposed additional discovery will be conducted promptly and efficiently. We understand the importance of adhering to the deadlines established by the court and will diligently work to ensure minimal disruption to the trial schedule. Both parties have cooperatively drafted this joint motion, underscoring our commitment to a fair and comprehensive legal process. Considering the significance of the newly discovered evidence and potential witnesses, we respectfully request the court's permission to proceed with the expanded discovery. We kindly ask that you acknowledge receipt of this joint motion and promptly provide us with a hearing date to present our case to the court. Should you require any additional information or have any concerns, please do not hesitate to contact me at [Your Email] or [Your Phone Number]. Thank you for your attention to this matter. We look forward to your favorable response. Sincerely, [Your Name] [Your Title (if applicable)]