[Your Name] [Your Address] [City, State, ZIP Code] [Date] [Recipient Name] [Recipient Address] [City, State, ZIP Code] Re: Entry of Appearance and Motion for Leave to File a Separate Amended Complaint Dear [Recipient's Name], I am writing to formally enter my appearance as counsel for the [Plaintiff/Defendant/Party] in the above-mentioned case pending before the [court name] in Contra Costa County, California. Please consider this letter as my formal entry of appearance. Furthermore, I hereby submit this motion for leave to file a separate amended complaint on behalf of my client. The proposed amended complaint seeks to make necessary modifications to the original complaint filed in this case, providing additional factual allegations and refining legal claims. The intent of filing the amended complaint is to ensure that a complete and accurate presentation of the facts and legal arguments is made before the court. The reasons behind seeking leave to file a separate amended complaint include: 1. Newly discovered evidence: Since the filing of the original complaint, my client has come across new evidence that supports the claims asserted. This evidence was previously unknown and was discovered after significant efforts in investigating the matter. 2. Clarification of legal claims: Upon further analysis of the case and consultations with expert witnesses, it has become evident that some aspects of the legal claims in the original complaint require refinement and clarification. The amended complaint will address these deficiencies and provide a more robust legal argument. 3. Preservation of judicial economy: By filing a separate amended complaint, my client aims to provide the court with a clear and concise presentation of the case, improving efficiency in the legal proceedings. I assure you that the proposed amended complaint is not intended to cause unnecessary delay or prejudice to any party involved. Rather, it is a necessary step to ensure justice and fairness in the resolution of this matter. It is my belief that granting leave to file a separate amended complaint is in the best interest of all parties involved and will facilitate a more accurate and comprehensive resolution of this case. In light of the above, I kindly request the court's permission to file the attached amended complaint as a separate pleading. I have also enclosed a copy of the proposed amended complaint for your review and consideration. Thank you for your attention to this matter. I eagerly await the court's ruling on this motion. Please do not hesitate to contact me should you require any additional information or documents. Sincerely, [Your Name] [Your Title/Position] [Law Firm Name (if applicable)] [Phone Number] [Email Address]