First Amended Complaint Sample Clauses
The First Amended Complaint is a legal document filed by a plaintiff to modify or supplement the original complaint in a lawsuit. This amendment may introduce new facts, add or remove parties, or clarify claims based on new information or developments in the case. By allowing changes to the initial pleading, the clause ensures that the lawsuit accurately reflects the current circumstances and issues, promoting fairness and procedural efficiency.
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First Amended Complaint. After the execution of this agreement, Plaintiff ▇▇▇▇▇▇’▇ complaint will be amended to replace ▇▇▇▇▇ ▇▇▇▇▇▇ with ▇▇▇▇▇▇▇▇ ▇▇▇▇▇ as the Plaintiff in this action and to add a cause of action under the Private Attorneys General Act of 2004 (PAGA).
First Amended Complaint. As a condition to this Settlement, Plaintiff will amend her original complaint and file a First Amended Complaint, inclusive of PAGA claims, to be filed by no later than July 15, 2022, which shall include the PAGA claim(s) articulated in her PAGA Notice and any other claims and
First Amended Complaint. For the purposes of effectuating this Agreement only, the Parties will stipulate that the Plaintiffs shall file a First Amended Class Action Complaint for Damages and Enforcement Under the Private Attorneys General Act, California Labor Code § 2698, et seq. in the Litigation, adding ▇▇▇▇▇▇▇▇ ▇▇▇▇▇▇▇ as a named Plaintiff and a cause of action to allege violations of PAGA (i.e., Operative Complaint).
First Amended Complaint. On October 30, 2017, Plaintiffs (now including ▇▇. ▇▇▇▇▇▇) filed a First Amended Complaint. The First Amended Complaint pleaded claims against Jeunesse, ▇▇▇▇▇ ▇▇▇▇▇, ▇▇▇▇▇ ▇▇▇, and ▇▇▇▇▇ ▇▇▇▇▇; repleaded claims against ▇▇▇ ▇▇▇, ▇▇▇▇ ▇▇▇▇▇▇, and ▇▇▇▇▇ ▇▇▇▇▇▇▇▇▇; and added two corporations—MLM Mafia, Inc., and Online Communications, LLC— allegedly related to ▇▇. ▇▇▇▇▇▇▇▇▇, as well as another Distributor, ▇▇▇▇▇ ▇▇▇▇▇▇▇. The First Amended Complaint sought the same unenforceability declaration with respect to the arbitration agreements executed by ▇▇. ▇▇▇▇▇▇▇ and ▇▇. ▇▇▇▇▇▇; the same claims for RICO violations and conspiracy to commit RICO violations; state law consumer fraud under the laws of Arizona (Ariz. Rev. Stat. § 44-1521, et seq.), Florida (Fla. Stat. §§ 501.204(1), 559.801, and 849.091); and Texas (Tex. Bus. & Com. Code § 17.41); claims for “federal securities fraud”; and a claim for “unjust enrichment.”
First Amended Complaint. The First Amended Complaint filed by Plaintiffs ▇▇▇▇▇▇▇ ▇▇▇▇▇ and ▇▇▇▇▇ ▇▇▇▇▇▇▇▇▇ in the case entitled ▇▇▇▇▇▇▇ ▇▇▇▇▇ et al.
First Amended Complaint. The First Amended Complaint filed in the Action by Plaintiff on April 12, 2022
First Amended Complaint. Prior to, or concurrent with the filing of the Motion for Preliminary Approval, Plaintiffs shall file a First Amended Complaint, substantially in the form of Exhibit E attached hereto, which shall become the operative complaint in the Action, adding Class Representative, ▇▇▇▇▇ ▇▇▇▇▇▇▇, as plaintiff and as a proposed Class Representative, and limiting the claims to ACH First Party Fees, and which shall not substantively change the complaint in any way except as set forth herein. Except as provided in Section 7.2 above, the Parties agree that no answer or response to the First Amended Complaint by BANA is required, and that BANA shall not be regarded as having admitted any allegations asserted against it.
First Amended Complaint. As part of the Joint Stipulation, at or before Plaintiff files a motion for preliminary approval, Plaintiff will file a First Amended Complaint to add in a cause of action for violations of the PAGA. Plaintiff will request the Court deem the First Amended Complaint filed and/or seek leave to file the First Amended Complaint prior to the preliminary approval hearing. The First Amended Complaint is attached hereto as Exhibit B.
First Amended Complaint. As part of this Agreement and in conjunction with obtaining preliminary approval of the Agreement, the Parties agree to stipulate that Plaintiff be granted leave to file a First Amended Complaint to add causes of action for failure to provide accurate, itemized wage statements and for civil penalties under the PAGA. Defendant shall cooperate, as necessary, to stipulate to and/or otherwise effectuate the filing of the First Amended Complaint. Defendant shall cooperate, as necessary, to with respect to Plaintiff sending a letter to the Labor & Workforce Development Agency asserting claims based on the allegations asserted in the proposed First Amended Complaint.