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

Case 3:01-cv-02296-RNC

Document 101

Filed 05/01/2008

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT : : : : VS. : : MELVIN WEARING, BRIAN SULLIVAN, : THOMAS TROCCHIO, EDWARD KENDALL, : ESTATE OF ANTHONY DILULLO, by Lisa : Bull DiLullo, Legal Representative,: JOHN DOES, RICHARD LEVIN, : LINDA LORIMER, RICHARD BRODHEAD, : THOMAS CONROY, and JAMES PERROTTI, : Defendants. : JAMES VAN DE VELDE, Plaintiff,

CIVIL NO. 3:01CV02296 (RNC)

MAY 1, 2008

MOTION FOR LEAVE TO AMEND COMPLAINT Plaintiff hereby moves, pursuant to Fed. R. Civ. P. 15, for permission to amend the complaint in this matter. thereof, plaintiff states as follows: 1. At the conclusion of the recent telephone conference in In support

this matter, the Court granted plaintiff's Motion for Reconsideration, and indicated that plaintiff would be permitted to file an amended pleading setting forth any further allegations he believed supported his claims, including those claims previously subject to an order of dismissal by the Court. 2. A proposed Second Amended Complaint is attached, in (The exhibits are the same as

unsigned form, and without exhibits.

those attached to the Amended Complaint, with one addition; the entire exhibit package will be served on opposing counsel).

Case 3:01-cv-02296-RNC

Document 101

Filed 05/01/2008

Page 2 of 3

Assuming there is no objection to its filing from the defendants, a signed Second Amended Complaint, with full exhibits, will be filed with the Court. WHEREFORE, for the foregoing reasons, plaintiff requests leave to amend his complaint in the form attached. THE PLAINTIFF JAMES VAN DE VELDE By_/s/David T. Grudberg ___________________________________ David T. Grudberg, ct01186 JACOBS, GRUDBERG, BELT & DOW, P.C. 350 Orange St. P.O. Box 606 New Haven, CT 06503 Ph.:(203) 772-3100 Fax:(203) 772-1691 Email: [email protected] James I. Meyerson 64 Fulton St. - Suite 502 New York, N.Y. 10038 Ph.:(212) 226-3310 Fax:(212) 513-1006 Email: [email protected] His Attorneys

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Case 3:01-cv-02296-RNC

Document 101

Filed 05/01/2008

Page 3 of 3

Certification The undersigned hereby certifies that a copy of plaintiff's Motion for Leave to Amend was transmitted electronically and/or mailed first class, postage pre-paid, on May 1, 2008 to: Stephen P. Fogerty, Esq. Robert A. Rhodes, Esq. Halloran & Sage LLP 315 Post Road West Westport, CT 06880 Aaron S. Bayer, Esq. Kenneth D. Heath, Esq. Wiggin & Dana One Century Tower New Haven, CT 06510 ______/s/David T. Grudberg David T. Grudberg

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