[Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] [Judge's Name] [Judge's Court] [Court Address] [City, State, ZIP] Re: Case No. [Case Number] [Plaintiff's Name] v. [Defendant's Name] Dear Judge [Judge's Last Name], I am writing to formally request an order granting our motion for leave to file a separate amended complaint in the above-mentioned case. We believe that the amendments proposed are crucial to accurately present the facts and legal claims in this matter, and we respectfully request the court's permission to file a separate amended complaint. Background: This case revolves around the alleged [describe the nature of the dispute], which occurred on [date]. The original complaint was filed on [date], and it has now become necessary to amend the pleading to reflect updated information and ensure a fair and just resolution. Proposed Amendments: The proposed amendments seek to rectify certain deficiencies, clarify factual allegations, and add new causes of action that have come to light through further investigation and discovery. The amended complaint will more accurately reflect the present circumstances, allowing for a clearer presentation of the claims and defenses. Justification for Separate Amended Complaint: Granting permission to file a separate amended complaint is necessary due to the extensive changes being made and to avoid confusion or the potential for disputes arising from merging the amendments into the existing complaint. By filing a separate amended complaint, we aim to provide the court and the opposing party with a clear and concise presentation of our claims, increasing efficiency and clarity throughout the litigation process. Case Impact: As a result of the proposed amendments, it is essential to allow for the filing of a separate amended complaint without prejudice to the original complaint. Granting this motion will promote fairness, prevent undue prejudice or confusion, and enable an accurate determination of the issues at hand. Conclusion: Based on the reasons stated above, we respectfully request the court to grant our motion for leave to file a separate amended complaint. Attached to this letter, please find a proposed separate amended complaint for your review and consideration. We appreciate the court's attention to this matter and the timely consideration of this request. If the court requires any further information or has any questions, please do not hesitate to contact us. Thank you for your time and understanding. Sincerely, [Your Name] [Your Law Firm Name] [Bar Number] [Email Address] [Phone Number] Enclosure: Proposed Separate Amended Complaint