Subject: Pennsylvania Sample Letter to Clerk for Filing Joint Motion for Leave to Propound Additional Discovery in a Civil Case Dear Clerk of the Court, I hope this letter finds you well. I am writing to formally request the filing of a Joint Motion for Leave to Propound Additional Discovery in the above-mentioned civil case pending before this honorable court. In accordance with the Pennsylvania Rules of Civil Procedure, specifically Rule XXX (insert relevant rule number), we, the undersigned parties (Plaintiff's Name and Defendant's Name), hereby jointly move for leave to propound additional discovery requests outside the normal time frame allowed under the Rules. The purpose of this motion is to facilitate the obtainment of critical evidence that has recently come to our attention and is crucial to the preparation of this case. Our grounds for this joint motion are as follows: 1. Newly Discovered Evidence: We have recently discovered new evidence that is material and relevant to the issues in dispute. This evidence could significantly impact the outcome of the case if admitted. 2. Good Cause: There is good cause to allow the additional discovery as it is essential to a fair and just resolution of this matter. The newly discovered evidence was not within the knowledge or control of any party prior to its discovery, and its exclusion would result in manifest injustice. 3. Timeliness: Despite the fact that this motion is filed outside the normal discovery period, it should be granted as soon as possible to avoid any undue delay in the proceedings. 4. Agreement between Parties: We, the undersigned parties, jointly and mutually agree to this motion and request that the court grant us leave to propound additional discovery. Therefore, we respectfully request that a hearing be scheduled at the earliest convenient date before the court to consider this motion. We also kindly request that the necessary copies of this Joint Motion for Leave to Propound Additional Discovery be filed and that we be promptly notified of any further required documentation or fees. Should you require any additional information or have any questions about this motion, please do not hesitate to contact me at the address or phone number provided below. Thank you for your attention to this matter. We look forward to a favorable response from the court. Yours sincerely, [Your Name] [Your Address] [City, State, ZIP Code] [Your Phone Number] [Your Email Address] cc: [Opposing Counsel] [Judge's Name]
Pennsylvania Sample Letter to Clerk for filing Joint Motion for Leave to Propound Additional Discovery
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(b) A motion to compel discovery must contain as exhibits the discovery requests and answers giving rise to the dispute. (c) A party may file a memorandum of law in support of its discovery motion or its response to a discovery motion.
Rule 4005 - Written Interrogatories (a) No party serving written interrogatories pursuant to the applicable Pennsylvania Rules of Civil Procedure shall serve upon any other party, as of right, more than fifty (50) interrogatories including interrogatories subsidiary to, or incidental to, or dependent upon, other ...
We don't like Motions to Compel. Judges don't like them, and neither do the opposing parties we bring them against. But they are, sometimes, required to be brought in cases where you need information to make sure you know what facts, witnesses and documents are in a case prior to going to going to trial.
Rule 1035.2 sets forth the general principle that a motion for summary judgment is based on an evidentiary record which entitles the moving party to judgment as a matter of law. The evidentiary record may be one of two types.
Rule 3117 - Discovery in aid of execution (a) Plaintiff at any time after judgment, before or after the issuance of a writ of execution, may, for the purpose of discovery of assets of the defendant, take the testimony of any person, including a defendant or a garnishee, upon oral examination or written interrogatories ...
Pennsylvania Rule of Civil Procedure 4019(a)(1)(i) provides that ?[t]he court may, on motion, make an appropriate order if a party fails to serve answers, sufficient answers, or objections to written interrogatories.?
(a) Subject to the provisions of Rules 4003.2 to 4003.5 inclusive and Rule 4011, a party may obtain discovery regarding any matter, not privileged, which is relevant to the subject matter involved in the pending action, whether it relates to the claim or defense of the party seeking discovery or to the claim or defense ...
Code § 2227 - Compulsory joinder. (a) Persons having only a joint interest in the subject matter of an action must be joined on the same side as plaintiffs or defendants.
