Case 1:16-cv-00095-NT Document 10 Filed 03/22/16 Page 1 of 2

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IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MAINE
GinA

CIVIL NO. 1:16-cv-00095-NT

Plaintiff
MOTION for LEAVE to AMEND COMPLAINT

with INCORPORATED MEMORANDUM OF LAW

Leigh Saufley, et al.,

FRCivP 15(a)(1)(A) and (a)(2)

Defendants

Plaintiff GinA files this Motion for Leave to Amend Complaint after reviewing Magistrate
Judge Nivisons March 16th Recommended Decision in 1:16-cv-00100-NT and identifying certain
legal and factual deficiencies with regard to her equal rights claims under 42 USC 1981.
As such, Plaintiff desires to exercise her right under FRCivP 15(a)(1)(A) and files this
Motion under FRCivP 15(a)(2) for Leave to Amend Complaint as she requested in her original
Complaint, Due to the public significance of the events cited in this complaint and GinAs need
to proceed without legal representation, GinA requests any necessary leave to correct any
technical or procedural errors or omissions which may cause this court to dismiss any part of the
complaint, in part or whole, sua sponte.
When this Court concludes its review of Plaintiffs complaint pursuant to 28 USC
1915(e)(2), Plaintiff has a reasonable expectation the Court will recommend at least a partial
dismissal sua sponte of the 42 USC 1981 claims for certain legal and factual deficiencies which
Plaintiff believes are correctable by providing additional information and by amending,
clarifying and supporting her current complaints allegations.
FRCivP 15(a)(1) allows Plaintiff to amend its pleading once as a matter of course
within: (A) 21 days after serving it, and Rule 15(a)(2) allows In all other cases, a party may
amend its pleading only with the court's leave. The court should freely give leave when justice
so requires.
Since the complaint has not yet been served nor the preliminary review completed,
Plaintiff desires to exercise her right under 15(a)(1)(A) to amend her complaint and requests

GinA v. Leigh Saufley

Motion for Leave to Amend Complaint

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Case 1:16-cv-00095-NT Document 10 Filed 03/22/16 Page 2 of 2

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leave under 15(a)(2) to "correct any technical or procedural errors or omissions" and add any
supporting facts, law and evidence.

WHEREFORE, Plaintiff respectfully moves this court pursuant to FRCivP 15(a)(2) to grant
her motion for leave to amend her complaint and set a reasonable deadline as riot to interfere
with the April 8, 2016 deadline recently set for filing her Amended Complaint in cv-00100-NT.

Respectfully submitted this 22nd day of March, 2016.

A~
GinA
2528 West River Road
Sidney, Maine 04330
{207) 209-1767
gina.ecf@gmail.com

GinA v. Leigh Saufley

Motion for Leave to Amend Complaint

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