[Your Name] [Your Address] [City, State, Zip Code] [Email Address] [Phone Number] [Date] [Recipient's Name] [Recipient's Designation] [Law Firm/Organization Name] [Address] [City, State, Zip Code] Subject: Entry of Appearance and Motion for Leave to File a Separate Amended Complaint Dear [Recipient's Name], I hope this letter finds you well. I am writing to formally enter my appearance as counsel for the plaintiff in the above-mentioned case and to seek permission from the court to file a separate amended complaint. 1. Background: [a brief description of the case, highlighting key facts and events related to the current complaint] 2. Purpose of the Motion: Explain the reasons for requesting leave to file a separate amended complaint. It is essential to provide a convincing argument and justify the necessity of an amended complaint. Focus on the relevance of the amendments and how they will strengthen the plaintiff's case. 3. Grounds for the Motion: [Enumerate the specific grounds on which the motion is based] a. Newly Discovered Evidence: Provided that new evidence has come to light that significantly impacts the case, explain its relevance, credibility, and how it supports the plaintiff's claims. b. Clarification of Claims: Describe how the proposed amendments will clarify and specify the claims made by the plaintiff, creating a stronger legal basis for the case. c. Legal Errors or Oversights: If there are any legal errors, inaccuracies, or omissions in the original complaint, address them and explain how the proposed amendments rectify those issues. d. Supporting Case Law: Refer to relevant case law that supports the plaintiff's right to file a separate amended complaint. 4. Compliance with Applicable Rules: Demonstrate the compliance with West Virginia's procedural rules in seeking leave to file a separate amended complaint. Cite the specific rules and regulations which outline the requirements for seeking such permission. 5. Relief Sought: Clearly state the relief sought in this motion, such as: a. Permission from the court to file a separate amended complaint within a specified time frame. b. An extension of the established deadline for filing the amended complaint. c. Any additional relief deemed necessary to ensure that justice is served. 6. Proposed Amended Complaint: Attach a copy of the proposed amended complaint along with the motion. Ensure that all amendments are clearly marked and identifiable. 7. Conclusion: Restate the purpose of the letter, emphasizing the necessity and relevance of filing a separate amended complaint. Express appreciation for the court's attention and cooperation. Thank you for your time and consideration. I look forward to your prompt response and the court's favorable decision regarding this motion. Should you have any queries or need further information, please do not hesitate to contact me. Sincerely, [Your Name] [Your Law Firm's Name] [Bar Number, if applicable]