E. PLAINTIFF’S MOTION FOR LEAVE TO AMEND THE COMPLAINT TO ADD COUNTS FOR NEGLIGENT MISREPRESENTATION, INTENTIONAL MISREPRESENTATIONS AND FRAUD AGAINST DEFENDANTS
Plaintiff requests this Court allow leave to file an Amended Complaint to add counts against JBI for negligent misrepresentation, intentional misrepresentation and fraud relating to Mr. Bordynuik's actions to induce Mr. Kaplanis to invest in JBI.
To the extent these actions were seemingly not done in Mr. Bordynuik's capacity as a corporate officer, Plaintiff also requests leave to amend the Complaint to add counts against Mr. Bordynuik for intentional misrepresentation and fraud. Plaintiff also requests leave to amend to add a count for breach of an oral agreement by Mr. Bordynuik relating to his promise of stock ownership, as detailed above.
Upon information and belief through the investigation of this matter in reviewing documents in the preparation of this pleading, Plaintiff?s counsel believes these counts are appropriate to supplement in an Amended Complaint in this matter.
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