Badgerow v. REJ Properties, Inc. et alMOTION for Leave to File Amneded ComplaintE.D. La.March 29, 20191 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA DENISE A. BADGEROW, on behalf of herself and a class of those similarly situated, Plaintiffs, v. REJ PROPERTIES, INC. D/B/A WALTERS, MEYER TROSCLAIR & ASSOCIATES, AND AMERIPRISE FINANCIAL SERVICES, INC. **************************************** * * * * * * * * * * * * * CIVIL ACTION NO.: 2:17-CV-9492 JUDGE: JAY C. ZAINEY MAGISTRATE: JOSEPH C. WILKINSON, JR. SECTION: A/2 ********************************* MOTION FOR LEAVE TO FILE PLAINTIFFS’ FIRST AMENDED AND SUPPLEMENTAL COMPLAINT COMES NOW the Plaintiffs, through undersigned counsel, and pursuant to Federal Rules of Civil Procedure 16 and 15, respectfully move this Court for leave to file a First Amended and Supplemental Complaint. Plaintiffs seeks leave to amend and supplement her Petition for Damages and Demand for Jury Trial to make the following changes: 1. Add Walters, Meyer, Trosclair & Associates, a Louisiana business partnership, and juridical entity pursuant to La. Civ. Code Art. 2801, as a Defendant. 2. Add Thomas Meyer as a defendant. 3. Add Greg Walters as a defendant. 4. Add Ray Trosclair as a defendant. In addition, Plaintiff desires to correct and/or clarify prior factual allegations contained in her Original Petition based on other additional information discovered since the filing of the Original Petition. Case 2:17-cv-09492-JCZ-JCW Document 125 Filed 03/29/19 Page 1 of 2 2 In accordance with Civil Local Rule 7.6, before filing this motion to amend pleadings the Plaintiffs attempted to obtain consent for the filing and granting of the motion from Defendants. However, Defendants oppose this motion. A copy of the proposed amended complaint is attached as Exhibit A. This Motion is based on the accompanying Memorandum in Support and the exhibits referenced therein. Respectfully Submitted: s/Amanda Butler, Esq. AMANDA J. BUTLER, ESQ. (T.A.) (La. 31644) STEPHANIE DOVALINA, ESQ. (La. 31137) BUSINESS LAW GROUP LLC 700 Camp St., Ste. 405 New Orleans, LA 70130 ATTORNEYS FOR PLAINTIFFS CERTIFICATE OF SERVICE I hereby certify that on this 28th day of March, 2019, a copy of the foregoing pleading was filed electronically with the Clerk of Court using the CM/ECF system. Notice of this filing will be sent to all counsel of record by operation of the court’s electronic filing system. s/Amanda Butler, Esq. AMANDA BUTLER, ESQ. 4845-6271-3744, v. 1 Case 2:17-cv-09492-JCZ-JCW Document 125 Filed 03/29/19 Page 2 of 2
