Case 1:19-cv-03377-LAP

Document 99

Filed 12/20/19

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## UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

- Case number: Civil Action No. 1:19-cv-3377 (LAP)
- Right column note: "Oral Argument Requested"

- Parties (names redacted or withheld in image):
  - Plaintiff: [REDACTED — black box]
  - Defendant: [REDACTED — name shown but withheld]
  - Counterclaim Plaintiff: [REDACTED — same as Defendant above]
  - Counterclaim Defendant: [REDACTED — black box]

- Layout: Two stacked boxed panels — top shows Complaint (Plaintiff v. Defendant); bottom shows Counterclaim (Counterclaim Plaintiff v. Counterclaim Defendant). Black bars redact two party names.

## NOTICE OF MOTION FOR LEAVE TO FILE AN AMENDED COMPLAINT

PLEASE TAKE NOTICE that upon the Declaration of Haley N. Proctor, dated December 20, 2019, together with the exhibits annexed thereto, and the accompanying memorandum of law, the undersigned will move this Court, before the Honorable Loretta A. Preska, United States District Judge for the Southern District of New York, at the United States Courthouse, 500 Pearl Street, New York, New York 10003, at a date and time to be determined by the Court, for an order under Rule 15(a) granting Plaintiff leave to file an amended complaint.

PLEASE TAKE FURTHER NOTICE that any response or objection to the motion should be made on or before January 17, 2020, in accordance with the Stipulation and Order dated

EFTA00027350

Case 1:19-cv-03377-LAP

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Filed 12/20/19

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November 26, 2019, Doc. No. 95. Any reply should be filed on or before January 24, 2020, in accordance with Local Rule 6.1(b).

Dated: December 20, 2019

/s/ Charles J. Cooper
Charles J. Cooper*
Michael W. Kirk*
Nicole J. Moss*
Haley N. Proctor*
COOPER & KIRK PLLC 
1523 New Hampshire Ave. NW
Washington, DC 74008
(202) 220-9600
*Admitted PHV

Attorney for Plaintiff

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Filed 12/20/19

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## CERTIFICATE OF SERVICE

I hereby certify that on December 20, 2019, I electronically filed the foregoing with the Clerk of the Court using the CM/ECF system, and I hereby certify that the foregoing was served upon all counsel of record using the CM/ECF system.

Is/ Charles J. Cooper
Charles J. Cooper*
COOPER & KIRK PLLC
1523 New Hampshire Ave. NW
Washington, DC 74008
(202) 220-9600
*Admitted PHV

Attorney for Plaintiff

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