Motion for Letter of Request

UNITED STATES DISTRICT COURT

FOR A SAMPLE DISTRICT

______________________________

) Case No.:

Peter Plaintiff, )

Plaintiff, )

)

v. )

)

Donald Defendant, )

Defendant. )

______________________________)

Moving Party: _______________

Respondent: _______________

MOTION FOR ISSUANCE OF

LETTER OF REQUEST

FOR

ORAL DEPOSITION IN FOREIGN JURISDICTION

The Moving Party hereby requests that this honorable court issue a Letter of Request directed to the appropriate judicial authority in the city of _______________, country of _______________ upon a date to be determined with proper notice provided, for the taking of an oral deposition of _______________ for the following reasons:

1. On or about the _____ day of _______________, 20_____, the Plaintiff commenced this action against the named Defendant pursuant to this court’s subject matter jurisdiction.

2. The date set (or required in conjunction with the applicable court rules) for the completion of discovery is the _____ day of _______________, 20_____.

3. As of this date, the following important, material issues in this case remain unresolved:

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