[Your Name] [Your Address] [City, State, ZIP Code] [Email Address] [Phone Number] [Date] [Judge's Full Name] [Judge's Designation] [Mecklenburg County Courthouse] [Address] [City, State, ZIP Code] Re: Case Name and Number Dear Honorable Judge [Judge's Last Name], I hope this letter finds you in good health. I am writing to respectfully request an order granting the motion for leave to file a separate amended complaint in the above-mentioned case. I represent [Plaintiff's Name], the plaintiff in this matter. Background: Provide a brief context of the case, mentioning the original complaint that was filed, its allegations, and any significant developments that have occurred since the initiation of the lawsuit. This section should offer a concise overview of the case's history and the need to file a separate amended complaint. Motion for Leave: Explain that the purpose of this letter is to support the pending motion for leave to file a separate amended complaint. Elaborate on the reasons why the plaintiff seeks to amend the original complaint and why a separate amended complaint is necessary. Grounds for Amendment: Discuss the grounds upon which the plaintiff bases the amendment. Provide a detailed explanation of the new facts, evidence, or claims that are discovered since the filing of the original complaint. Additionally, mention any legal analysis that supports the reason for seeking the amendment. Relevant Case Law: Cite pertinent case law from Mecklenburg County or North Carolina that supports the plaintiff's right to file a separate amended complaint. This will strengthen the argument for granting the motion. Prejudice to the Defendant: Address any potential concerns regarding prejudice to the opposing party caused by filing a separate amended complaint. Explain that the defendant will not be substantially disadvantaged by the amendment, and that any potential delay or inconvenience can be effectively managed by the court. Proposed Amended Complaint: Provide a copy of the proposed amended complaint, highlighting the changes and additions made from the original complaint. Ensure that the amended complaint adheres to all procedural requirements and follows the court's rules. Conclusion: Reiterate the importance of granting the motion for leave to file a separate amended complaint and thank the court for considering this request. Offer your availability for any further clarification or hearing that the court may require. Yours sincerely, [Your Name] [Your Law Firm Name, if applicable] [Your Bar Association Identification Number] (if applicable)