Plaintiffs seek to amend the complaint

Plaintiffs move for leave to file an amended verified complaint under Federal Rule of Civil Procedure 15(a). The proposed amended complaint is included as an attachment in the ECF filing.

Plaintiffs’ counsel have consulted with Defendants’ counsel seeking consent to the filing of the amended complaint and asking whether Defendants oppose this motion for leave to file the amended complaint. Defendants’ counsel advised Plaintiffs’ counsel on October 30, 2015 as follows: “We do not consent to the amended complaint and oppose a motion for leave to amend.”

Defendants’ counsel provided no explanation for those responses.

Please click on the links below to read the full documents (the request to file an amended complaint and the amended complaint).

D.32 motion for leave to file amended complaint (October 20, 2015)

D.32-1 motion for leave to file – attachment (am compl) (October 20, 2015)