Fill and Sign the Draft Plaintiffs Motion to Amend Complaint Greenville County Form

IN THE CIRCUIT COURT OF ____________________________ COUNTY, ALABAMA MOTION TO AMEND COMPLAINT COME NOW the plaintiffs, by and through their undersigned counsel, and hereby move this honorable court for an order making ______________________________, a party defendant herein and directing the issuance and service of process on it, and for grounds therefore shows: 1. This action is a ________________________ claim in which the original complaint was filed with this court on ________________________________; 2. Since the original compliant was filed on ____________________________ the Plaintiffs have discovered an additional party which was unknown to the Plaintiffs when the original complaint was filed;3. _______________________________, is an indispensable, necessary and proper party defendant because they may have been the entity which performed the fireworks display; 4. The said ________________________________ is incorporated/resident of ______________________________, doing business in Alabama and therefore subject to the jurisdiction of this court as both service of process and venue and can be made a party defendant herein without depriving the court of jurisdiction. Done this the ________________ day of _____________, ____________. Respectfully submitted,PlaintiffsOF COUNSEL:____________________________________________________________________________________By _______________________________________, Alabama _______ ________________________________________________________ ______________________________ ____________________________Attorneys for Plaintiff CERTIFICATE OF SERVICE I hereby certify that I have served a copy of the foregoing via U.S. Mail, postage prepaid, upon _____________________________ (name), ______________________ (address), ____________________ (city), Alabama ___________________ (zip code), and _____________________ (name),_________________________ (company), and _________________________ (name), __________________________ (address), _____________________ (city), PA, ______________ (zip code), on this day of ______________________, _______. ______________________________ ____________________________