COMMONWEALTH OF MASACHUSETTS
WORCESTER, SS
SUPERIOR COURT
C.A.
No. 1685CV00217 D
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GORDON T. DAVIS, Plaintiff
Vs.
TURTLEBOY SPORTS INC.,
AIDEN KEARNEY,
Defendants
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PLAINTIFF’S
REQUEST TO AMEND COMPLAINT TO ADD NEW COUNT OF LIBEL
Plaintiff,
Gordon T. Davis, hereby requests this honorable Court for leave to amend his
complaint pursuant to Massachusetts Civil Proceeding Rule 15. This request is
after the filing of the original Complaint and before the filing of the Answer
Pleading.
The
amendment is to add a new count of libel against the Defendants. In February
2016 after the filing of the original Complaint the Defendants again libeled
the Plaintiff by publishing that he is mentally unstable, senile, and crazy.
(Exhibit 1).
As grounds
therefore avers to the following: 1. this lawsuit was filed on February 12,
2016 and served upon the Defendants on February 19, 2016. During the week of February 21, 2016 the
Defendants published the libel found in Exhibit 1.
The
Plaintiff respectfully requests the Court for leave to amend his Complaint as
seen above.
Respectfully
submitted,
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Gordon T. Davis
Date
Pro Se Plaintiff
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