Free Motion to Amend/Correct - District Court of Connecticut - Connecticut

Case 3:03-cv-00940-RNC

Document 15

Filed 01/30/2004

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT MARIA DEGENNARO, : : Plaintiff, : : vs. : : EXPANETS, INC. n/k/a NETEXIT, INC., : et al., : : Defendants. : CIVIL ACTION NO. 3:03-CV-940-RNC

January 30, 2004

PLAINTIFF'S UNOPPOSED MOTION TO AMEND THE COMPLAINT. Pursuant to Rules 15 and 20 of the Federal Rules of Civil Procedure, Plaintiff, Maria DeGennaro, hereby moves to amend her Complaint to join Netexit, Inc., Netexit of North America, LLC and Avaya, LLC as additional defendants in this proceeding as successors in interest to Defendants, Expanets, Inc. n/k/a Netexit, Inc. and Expanets of North America, LLC n/k/a Netexit of North America, LLC. For the reasons explained in the accompanying Memorandum of Law, Plaintiff's Motion should be granted and Plaintiff should be permitted to file and serve an Amended Complaint in the form attached as Exhibit "A" to the accompanying Memorandum. Respectfully submitted,

James E. Miller, Esquire Federal Bar No. CT-21560 Shepherd Finkelman Miller & Shah, LLC One Lewis Street Hartford, CT 06103 (Tel) (860) 246-0600 (Fax) (860) 246-0700

ORAL ARGUMENT NOT REQUESTED

Case 3:03-cv-00940-RNC

Document 15

Filed 01/30/2004

Page 2 of 2

Attorney for Plaintiff

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