amendment plea.docx

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To the Court: Although the Universal Rules of the Municipal courts do not require taking leave of the Court in order to amend the pleadings, I wish to explain my request for an amendment at this time,and that I have not been dilatory in doing so. To serve the interests of justice and truth,and those of my client, it is necessary that I amend one sentence of my defensive pleading in response to the defendant’s counterclaim. I have spoken with opposing counsel, and he………………………. I filed my defensive pleadings in November, 2013 with the knowledge and understanding that I had at that time of the evidence. When I received my notice of the hearing on or about February 5, 2014, I made arrangements to meet with my client to discuss the trial preparation the following week of February 10, 2014. Due to weather delays, the first day that we were able to meet was Friday, February 14. In reviewing all of the evidence at that time, I realized that I had made an error in the defensive pleadings, and now seek to amend that mistake. I respectfully request that my amendment be permitted to be filed and become part of the pleadings in this case. I also respectfully request that neither my client nor her opponent be penalized by another continuance of this case, since it has already been continued three times, per the request of the defendant and his counsel. What else do I need?

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To the Court:Although the Universal Rules of the Municipal courts do not require taking leave of the Court in order to amend the pleadings, I wish to explain my request for an amendment at this time,and that I have not been dilatory in doing so. To serve the interests of justice and truth,and those of my client, it is necessary that I amend one sentence of my defensive pleading in response to the defendants counterclaim. I have spoken with opposing counsel, and he.I filed my defensive pleadings in November, 2013 with the knowledge and understanding that I had at that time of the evidence. When I received my notice of the hearing on or about February 5, 2014, I made arrangements to meet with my client to discuss the trial preparation the following week of February 10, 2014. Due to weather delays, the first day that we were able to meet was Friday, February 14. In reviewing all of the evidence at that time, I realized that I had made an error in the defensive pleadings, and now seek to amend that mistake. I respectfully request that my amendment be permitted to be filed and become part of the pleadings in this case. I also respectfully request that neither my client nor her opponent be penalized by another continuance of this case, since it has already been continued three times, per the request of the defendant and his counsel. What else do I need?