[Your Name] [Your Address] [City, State, ZIP Code] [Email Address] [Phone Number] [Date] [Judge's Name or Clerk of Court] [Address of Court] [City, State, ZIP Code] Re: Entry of Appearance and Motion for Leave to File a Separate Amended Complaint Case No: [Case Number] Dear [Judge's Name or Clerk of Court], I, [Your Full Name], hereby enter my appearance as the [Plaintiff/Defendant's] legal representative in the above-mentioned case. I am writing to request permission from the honorable court to file a separate amended complaint on behalf of my client. The nature of this case involves an alleged [briefly mention the main issue or cause of action being pursued]. It has become apparent to me, upon further review and investigation, that certain crucial facts and evidence were inadvertently not included in the original complaint. To rectify this deficiency, I respectfully request the court's permission to file a separate amended complaint that will adequately address these pertinent facts and strengthen our client's position. Key Facts Supporting the Motion: 1. Newly Uncovered Evidence: After thorough research and consultation with experts in the field, we have uncovered substantial evidence that was previously unknown and was not present at the time of filing the original complaint. This evidence is crucial to bolstering our client's claims and provide a comprehensive understanding of the case. 2. Legal Merit: The proposed amended complaint seeks to assert valid legal claims that are supported by both existing case law and statutory provisions. It is our firm belief that the amendments sought will strengthen our client's position and ensure a fair and just resolution of this matter when considered in conjunction with the original complaint. 3. Absence of Prejudice: We hereby affirm that the filing of a separate amended complaint will not prejudice any party involved. All relevant parties will be promptly served with copies of the amended complaint, ensuring a transparent and open legal process, which adheres to the principles of fundamental fairness. In light of the above, I kindly request the honorable court to grant our motion for leave to file a separate amended complaint. Our intent is not to cause undue delay or prejudice; rather, it is driven solely by our dedication to presenting the most accurate and complete version of the facts before this court. Thank you for your attention to this matter. I appreciate your consideration of our request and look forward to your favorable response. Sincerely, [Your Full Name] [Your Title] [Law Firm Name, if applicable] [Bar Number, if applicable]