Public Engines v. Reportsee

Filing 55

MOTION for Leave to File First Amended Complaint filed by Plaintiff Public Engines. Motions referred to Samuel Alba.(Haws, J.)

Public Engines v. Reportsee

Doc. 55

Alan L. Sullivan (3152) Todd M. Shaughnessy (6651) J. Elizabeth Haws (11667) Snell & Wilmer L.L.P. 15 West South Temple, Suite 1200 Beneficial Tower Salt Lake City, Utah 84101-1004 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiff UNITED STATES DISTRICT COURT DISTRICT OF UTAH, CENTRAL DIVISION

PUBLIC ENGINES, INC., a Delaware Corporation, Plaintiff, vs. REPORTSEE, INC., a Delaware Corporation, Defendant.

MOTION FOR LEAVE TO FILE FIRST AMENDED COMPLAINT Case No. 2:10-cv-317 Honorable Tena Campbell

Pursuant to Rule 15(a) of the Federal Rules of Civil Procedure, Plaintiff Public Engines, Inc. moves this Court for leave to file an Amended Complaint in the form appended to the accompanying Memorandum in Support of Motion for Leave to File First Amended Complaint as Exhibit 1. The basis for this motion is that Plaintiff has identified an additional party who is jointly and severally liable along with the existing defendant for the damages suffered by Plaintiff. Although this additional party may provide alternative avenues of recovery, the amendment does not materially change the substantive allegations of this case. Accordingly, Plaintiff requests that leave be granted, as permitted by Rule 15(a)'s liberal standard. This motion is supported by the accompanying memorandum filed concurrently herewith, and by the pleadings and papers on file in this matter.

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DATED this 29th day of October 2010. SNELL & WILMER L.L.P.

By /s/ J. Elizabeth Haws Alan L. Sullivan Todd M. Shaughnessy J. Elizabeth Haws Attorney for Public Engines, Inc.

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CERTIFICATE OF SERVICE I hereby certify that on the 29th day of October, 2010, I served the foregoing MOTION FOR LEAVE TO FILE FIRST AMENDED COMPLAINT by the CM/ECF filing system on the following: Joshua A. Glikin 29 W. Susquehanna Ave., Suite 600 Towson, MD 21204 [e-mail] Jeffrey J. Hunt David C. Reymann Parr Brown Gee & Loveless 185 South State Street, Suite 800 Salt Lake City, UT 84111 [e-mail] [e-mail] Walter Diercks Rubin, Winston, Diercks, Harris & Cooke, L.L.P. 1201 Connecticut Ave., NW, Suite 200 Washington, DC 20036 [e-mail]

/s/ J. Elizabeth Haws

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