Wyoming Sample Letter for Motion to Strike Plaintiff's Amended Complaint and Second Amended Complaint [Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] [Recipient's Name] [Recipient's Position] [Recipient's Address] [City, State, ZIP] Re: Case No. [Case Number] Plaintiff: [Plaintiff's Name] Defendant: [Defendant's Name] Motion to Strike Plaintiff's Amended Complaint and Second Amended Complaint Dear [Recipient's Name], I hope this letter finds you well. I am writing on behalf of my client, [Defendant's Name], in regard to the above-mentioned case. We hereby submit this motion to strike the Plaintiff's Amended Complaint and Second Amended Complaint based on the following grounds: 1. Lack of procedural diligence: The Plaintiff has demonstrated a lack of diligence by repeatedly amending their complaint without proper cause or justification. The original complaint adequately presented the issues at hand, and subsequent amendments unduly burden the Defendant's ability to prepare a defense. 2. Prejudice to the Defendant: The Plaintiff's multiple amendments have caused prejudice to the Defendant. It has become increasingly difficult for the Defendant to respond effectively and prepare a comprehensive defense due to the continual changing of factual allegations and legal theories. 3. Failure to meet legal standards: The Plaintiff's Amended Complaint and Second Amended Complaint fail to satisfy the necessary legal standards for pleading. The amended versions include superfluous and irrelevant information that does not contribute to a clear understanding of the claims. This lack of clarity hinders the Defendant's ability to mount an appropriate defense. 4. Waste of judicial resources: Allowing the Plaintiff's amended complaints to stand would result in an unnecessary waste of judicial resources. The constant amendments prolong the litigation process, burdening the court with additional time and effort that could be better utilized on matters of greater importance. Considering the aforementioned reasons, we respectfully request that the court grant our motion to strike the Plaintiff's Amended Complaint and Second Amended Complaint. Such a ruling would allow for a focused and fair proceeding going forward, preventing further prejudice to the Defendant and ensuring an efficient dispensation of justice. We trust that the court will consider our motion carefully and make a decision in line with the principles of justice and fairness. Please find attached a copy of the Notice of Motion and Motion to Strike Plaintiff's Amended Complaint and Second Amended Complaint for your reference. Thank you for your attention to this matter. We appreciate your prompt consideration. Sincerely, [Your Name] [Your Title] [Law Firm Name] [Law Firm Address] [City, State, ZIP]