Chapter 2 - FORM 2-12 : MOTION TO AMEND COMPLAINT TO ADD DEFENDANT IDENTIFIED AS NONPARTY AT FAULT

• Jurisdiction: Colorado

Form 2-12: Motion to Amend Complaint to Add Defendant Identified as Nonparty at Fault

District Court, __________ County, Colorado Court Address:	▲ COURT USE ONLY ▲
Plaintiff(s): v. Defendant(s):
Attorneys for Plaintiff (Name and Address) Phone Number: FAX Number: E-mail: Atty. Reg. #:	Case Number: Div.: Ctrm.:
MOTION TO AMEND COMPLAINT

Plaintiff [name of plaintiff], by and through its counsel [name of plaintiff's attorney], submits this Motion to Amend Complaint. For its Motion, Plaintiff sets forth the following:

CERTIFICATION

Pursuant to C.R.C.P. 121 § 1-15(8), counsel for Plaintiff has conferred with counsel for Defendants. Counsel for Plaintiff is authorized to state that counsel for Defendants has no objection to the relief requested in this Motion.

MOTION

1. On [date] Plaintiff filed its Complaint.

2. In its Complaint, Plaintiff alleged that Defendants [names of defendants] were [specify nature of cause of action, such as: were negligent in that they (summary of specific allegations)].

3. After filing their Answers, Defendants each filed Designations of Non-Parties at Fault pursuant to C.R.S. § 13-21-111.5. Each Defendant designated [name of potential new defendant] as a non-party at fault.

4. As set forth in Defendant [name of defendant]'s designation: [describe why the inclusion of the additional defendant is appropriate, such as the proposed additional defendant manufactured a part contained in the allegedly defective product, or describe the proposed additional defendant's involvement in causing the damages to the plaintiff].

5. To determine the validity of the Defendants' various...