IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT IN AND
FOR BREVARD COUNTY, FLORIDA
CASE NO.: 05-2007-CA-XXXXX-XXXX-XX
PLAINTIFF’S MOTION FOR LEAVE TO AMEND COMPLAINT
Plaintiff, John Doe, by and through undersigned counsel, moves the court for leave to serve and file an amendment to Plaintiff's complaint in the above-entitled action pursuant to Fla.R.Civ.P. 1.190(a), Pasekoff v. Kaufman, 392 So.2d 971, 976 (3rd DCA Fla. 1981), and Turner v. Trade-More, Inc., 252 So.2d 383 (4th DCA Fla. 1971), Yun Enterprises Ltd. v. Graziani, 840 So.2d 420 (Fla. 5d 2003) on the grounds that the proposed amendment and the evidence offered under it are necessary to a complete determination of the issues in this action and the rights of the parties. A copy of the proposed amended complaint is attached.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via U.S. Mail to Other Lawyer, Address, on this _____ day of ________________, 2008.
Michael B. Lesage
815 South Washington Ave
Attorney for the Plaintiff