Defendant mailed 1. Motion for demurrer 2. Plea in bar and 3. A Memroandum in support of plea in bar.
Question. Am pro se and am thinking of filing a motion for leave to amend my complaint.. do I have to write 3 different documents in response to all 3 items or will my amended complaint along with the motion address all items at once.
Am in VA
1 Answer from Attorneys
I'd say you can write a single memo in opposition to both the demurrer and plea in bar, separating the arguments with Roman numeral point headings. You can call the document "Plaintiff's Memorandum in Opposition to Demurrer and Plea in Bar." Make sure you're in time under the Rules. The amended complaint is of course a separate document. Your motion for leave to amend should adhere to (and cite) Rule 4:15. Take care to observe the timing requirements. Contact the clerk's office if in doubt about how scheduling works--in the larger jurisdictions there are scheduling hearings, i.e. in-person appearances just to set a hearing date. Good luck.