MOTION FOR LEAVE TO FILE AMENDED COMPLAINT P a g e | 1

IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT

IN AND FOR BREVARD COUNTY, FLORIDA

Name, AKA, )
, )
Plaintiff, ) CASE # 05-2010-CC-0_____-XXXX-XX
)
-vs- )
)
Name, et al. )
Defendant. )


MOTION FOR LEAVE TO AMEND COMPLAINT

Comes now, the plaintiff, Name, pro se Plaintiff, hereby moves pursuant to Florida rules of Civil
Procedure 1.190(a), and seeks leave to amend the complaint.
1. The proposed amended complaint, which is attached, is purposed to add the additional
statutory causes of action based on alleged transactions.
2. The defendant will not be prejudiced by the amendment of the complaint, nor will the
amendment warrant additional time for discovery in this case.
WHEREFORE, the plaintiff respectfully requests that an Order granting this motion for leave to
amend the complaint and this amended complaint be entered as the filed amendment accepted by
this court.

I HEREBY CERTIFY that a true and correct copy of the foregoing was mailed by U.S. mail this
_20th_ day of _June_, 2014 to: _ Name , Address, City, State, Zip__________________
______________________________
Date Signed Petitioners Signature
_______ ___ _____________
Daytime Phone Address
___ ________




MOTION FOR LEAVE TO FILE AMENDED COMPLAINT P a g e | 2





MOTION FOR LEAVE TO FILE AMENDED COMPLAINT P a g e | 3

Be certain to copy amended complaint and attach to motion


Boca Burger,Inc. v. Forum, 912 So.2d 561 (Fla. 2005)
Cited as Right to Amend Pleading from FL Civ. Trial Prep., Pg. 52

Posey v. Magill, 530 So. 2d 985 (Fla. 1
st
DCA 1988)
Cited to asset additional causes of action


Rules/Statutes-REFERENCE ONLY!

1. Fla. Stat. 726.102 (12)
He disposed of an interest in an asset through the creation of a lien
2. Fla. Stat. 726.103 (4)
He has attempted to conceal assets with the intent to defraud creditors and includes
voidable transfers. This prevents him from claiming insolvency.
3. Fla. Stat. 726.105 (1)(a)(b)
He has delayed the security of the assets in an attempt to defraud me and /or without
providing a value for exchange of the obligation.
4. Fla. Stat. 726.105(1)(b)(2)
He was unable to pay the debt as it became due, consistently claims indigence, although I
have approached him many times at his workplace.


Trawicks Florida practice & Procedure Amendments 14.4
Thereafter on a proper attack the ocurt can rule the amendment is legally insufficient.
The simpler way to accomplish the filing and service of an amended pleading is to have
the order make the proposed amendment stand as the filed amendment. This saves filing
and serving a duplicate. The amended pleading follows the form of the pleading it
replaces, except for the designation as an amended pleading.
PG. 252