Sample Letter for Entry of Appearance and Motion for Leave to File a Separate Amended Complaint in San Jose California [Your Name] [Your Address] [City, State, ZIP Code] [Email Address] [Phone Number] [Date] [Judge's Name] [Judge's Designation] [San Jose Courthouse] [Address] [City, State, ZIP Code] Re: [Case Name and Number] Appearance and Motion for Leave to File a Separate Amended Complaint Dear Judge [Judge's Last Name], I hope this letter finds you well. I am writing to officially enter my appearance as counsel for the [Plaintiff/Defendant] in the above-mentioned case. Additionally, I respectfully request the Court's permission to file a separate amended complaint as detailed below. 1. Background: Briefly provide an overview of the case, including the parties involved and the primary legal issues. Explain the current status of the proceedings and any relevant court orders or prior motions. 2. Basis for the Motion: Explain the valid reasons why the plaintiff/defendant seeks leave to file a separate amended complaint. These reasons may include additional factual or legal considerations that have arisen since the original complaint, the need to present new claims or defenses, or an unintended error or omission in the previous filing. 3. Legal Standard: Provide a concise explanation of the legal standard applicable to the filing of an amended complaint and the criteria the court may consider in granting or denying the motion. Cite relevant case law or statutes specific to San Jose, California if necessary. 4. Proposed Amended Complaint: Attach a copy of the proposed amended complaint as an exhibit to the motion, highlighting the specific changes or additions made to the original complaint. Clearly explain how the amended complaint complies with the applicable rules of court and properly asserts the new or revised claims or defenses, if any. 5. Impact on the Case: Describe how the filing of a separate amended complaint will affect the overall proceedings, the parties involved, and any potential prejudice or inconvenience that may arise. Address any possible delay or disruption and propose appropriate mitigation measures, if applicable. 6. Conclusion: Summarize the key points presented in the motion and restate the request for the Court's permission to file a separate amended complaint. Express your willingness to comply with any additional requirements or orders provided by the Court. I appreciate the Court's attention to this matter and request expedited consideration of this motion. Please let me know if there are any scheduling conflicts or if you require any further documentation or clarification. Thank you for the opportunity to present this motion. I look forward to your favorable ruling regarding the entry of appearance and permission to file a separate amended complaint. Yours sincerely, [Your Name] [Your Law Firm Name] [Bar Number]