Pennsylvania Sample Letter regarding Order Granting Motion for Leave to File a Separate Amended Complaint [Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] Honorable [Judge's Name] [Court Name] [Court Address] [City, State, ZIP] Re: Case No. [Case Number] Dear Honorable [Judge's Name], I hope this letter finds you in good health. I am writing to bring your attention to a recent development in the above-mentioned case and request your approval for the filing of a separate amended complaint. On behalf of the plaintiff, [Plaintiff's Name], we hereby submit this motion seeking leave to file a separate amended complaint. Our motion is based on the following grounds: 1. Discovery process: As we proceed with the discovery process, new evidence has come to light that necessitates the filing of an amended complaint. The information obtained through this process has provided us with a clearer understanding of the facts and circumstances of the case, which was not available to us when we initially filed the complaint. 2. Additional claims: The discovery process has also enabled us to identify additional claims that should be included in the amended complaint. These claims arise from the same set of circumstances and are essential for the complete resolution of the issues at hand. Including these claims will prevent potential prejudice as well as ensure a comprehensive presentation of the plaintiff's case. 3. Consolidation: It is crucial to note that the filing of a separate amended complaint does not intend to disrupt or delay the proceedings in any manner. We propose that the amended complaint be consolidated with the existing complaint for the purpose of efficiency and avoiding duplication. Consolidation will allow the court to consider all the relevant claims and facilitate a fair and expeditious resolution of the case. Considering the aforementioned grounds, we respectfully request that this honorable court grant our motion for leave to file a separate amended complaint. We assure you that the necessary amendments have been drafted with the utmost care and attention to detail, and we have attached a copy of the proposed amended complaint for your review. We understand the importance of maintaining the efficiency of the legal process and are committed to ensuring a fair and prompt resolution of this case. Furthermore, we would be grateful for the court's favorable consideration of our motion. Thank you for your attention to this matter, and we look forward to your favorable order granting our motion. Sincerely, [Your Name] [Your Law Firm's Name] [Attorney at Law] Enclosure: Proposed Amended Complaint