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1:14-cv-00406 #48

1:14-cv-00406 #48

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Published by Equality Case Files
Doc 48 - Plaintiffs' motion to file amended complaint (w/amended complaint attached)
Doc 48 - Plaintiffs' motion to file amended complaint (w/amended complaint attached)

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Published by: Equality Case Files on Jun 06, 2014
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06/06/2014

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION OFFICER PAMELA LEE,
et al.,
) ) Plaintiffs, ) ) -vs- ) ) MIKE PENCE, in his official capacity ) Cause No: 1:14-cv-406-RLY-TAB as Governor of the State of Indiana,
et al.
 ) ) Defendants. )
PLAINTIFFS UNOPPOSED MOTION FOR LEAVE TO FILE AMENDED COMPLAINT
 Plaintiffs, Officer Pamela Lee, Candace Batten-Lee, Officer Teresa Welborn, Elizabeth J. Piette, Battalion Chief Ruth Morrison, Martha Leverett, Sergeant Karen Vaughn-Kajmowicz, Tammy Vaughn-Kajmowicz and J.S.V., T.S.V. and T.R.V. ("Children"), by their parents and next Friends, Sergeant Karen Vaughn-Kajmowicz and Tammy Vaughn-Kajmowicz, by counsel, respectfully request that they be granted to leave to file an amended complaint. In support of their motion, plaintiffs state as follows: 1. Plaintiffs seek leave to amend their complaint to address the following: a. Paragraph 10: The amendment simply adds Sergeant Vaughn-Kajmowicz; b. Paragraph 17: This is now changed to accurately reflect where Chief Morrison and Martha Leverett were actually married; c. Paragraphs 37 and 38: As noted by the defendants, there were two
Case 1:14-cv-00406-RLY-TAB Document 48 Filed 06/05/14 Page 1 of 3 PageID #: 555
 
 2
paragraphs 37 and two paragraphs 38. The amended now identifies each of the four paragraphs as identified by the defendants in their answer, i.e., paragraphs 37[a], 37[b], 38[a] and 38[b]; d. Count III: The amended complaint no longer contains allegations regarding a violation of the Full Faith and Credit Clause. 2. This amendment is being sought so as to make certain the record is accurate should this matter be further adjudicated beyond this Court. 3. The proposed changes are not substantive except for the abandonment of Count III and none of the changes prejudice the defendants. 4. Counsel for defendants has no objection to this amendment. WHEREFORE, the plaintiffs respectfully request that they be granted leave to file the amended complaint which is attached hereto. Respectfully submitted,
 /s/Karen Celestino-Horseman
 Karen Celestino-Horseman Of Counsel, Austin & Jones, P.C. One N. Pennsylvania St., Ste. 220 Indianapolis, IN 46204 Tel: (317) 632-5633 Fax: (317) 630-1040 E-mail: Karen@kchorseman.com 
Case 1:14-cv-00406-RLY-TAB Document 48 Filed 06/05/14 Page 2 of 3 PageID #: 556
 
 3
CERTIFICATE OF SERVICE
 The undersigned hereby certifies that a copy of the foregoing
Uncontested Motion  for Additional Pages
was filed electronically on June 4, 2014. Notice of this filing will be sent to the following counsel by operation of the Court’s electronic filing system. Parties and counsel may access this filing through the Court’s System. Thomas M. Fisher
 
Solicitor General
 
Office of the Attorney General 302 W. Washington St.,
 
IGCS 5th Floor
 
Indianapolis, IN 46204-2770
 
Email: Tom.Fisher@atg.in.gov 
 /s/Karen Celestino-Horseman
 Karen Celestino-Horseman Of Counsel, Austin & Jones, P.C. One N. Pennsylvania St., Ste. 220 Indianapolis, IN 46204 Tel: (317) 632-5633 Fax: (317) 630-1040 E-mail: Karen@kchorseman.com
 
Case 1:14-cv-00406-RLY-TAB Document 48 Filed 06/05/14 Page 3 of 3 PageID #: 557

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