Subject: New Jersey Sample Letter for Motion to Strike Plaintiff's Amended Complaint Dear [Recipient's Name], I hope this letter finds you in good health and high spirits. I am reaching out in regard to the recent developments pertaining to the plaintiff's amended complaint in [Case Name], filed in [Court Name], New Jersey. In light of this amendment, we believe it is necessary to file a motion to strike the plaintiff's amended complaint, as it fails to meet the established legal requirements and lacks merit. We have prepared a comprehensive sample letter for your convenience and consideration. [Type 1 — General Motion to Strike Plaintiff's Amended Complaint]: The purpose of this motion is to request the court to strike the plaintiff's amended complaint in its entirety on the grounds that it violates the procedural rules set forth by the New Jersey court system. Our argument is based on the following grounds: 1. Failure to Comply with Court Orders: The plaintiff is in violation of the court's orders by amending their complaint without proper approval or consent. By proceeding without court authorization, the plaintiff has shown a disregard for the court's procedural standards and is therefore inappropriate. 2. Lack of Amendment Merit: The amended complaint fails to state any new and relevant facts or legal theories that warrant consideration by the court. The plaintiff's amendments are merely cosmetic and do not rectify the fundamental flaws identified in the original complaint. 3. Prejudice to the Defendant: Allowing the plaintiff's amended complaint to proceed would cause undue prejudice to the defendant. The delay and additional expenses associated with re-arguing the case based on these new claims would be burdensome and unfair. [Type 2 — Motion to Strike Specific Portions of Plaintiff's Amended Complaint]: In this alternative motion, we request the court to strike specific portions of the plaintiff's amended complaint that are immaterial, impertinent, or scandalous. This motion argues that certain allegations or claims made in the complaint are intended to be prejudicial, serve no legitimate purpose, or smear the defendant's reputation. We firmly believe that our motions hold strong legal and factual merits. It is our contention that by granting this motion, the court can uphold the principles of fairness and justice, while protecting the rights of the defendant. Attached with this letter, you will find a detailed sample letter for the motion to strike the plaintiff's amended complaint, along with supporting legal briefs and exhibits. Please feel free to review and modify the content based on your specific requirements. Should you have any questions or require any additional information, please do not hesitate to reach out to us at your earliest convenience. We are ready to collaborate with you to ensure a favorable outcome in this case. Thank you for your attention to this matter. Sincerely, [Your Name] [Your Law Firm's Name] [Contact Information]