Motion for Leave to File Amended Pleading

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                          CAUSE NO. 2016-86829

FIRST BANK
Plaintiff,

IN THE DISTRICT COURT OF

VS.
KOPPER FUNDING CORPORATION and

NICOLAS M. BAZAN, P.C

Defendants.

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§ | HARRIS COUNTY, TEXAS
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§ 165™ JUDICIAL DISTRICT

MOTION FOR LEAVE TO FILE AMENDED PLEADING

COMES NOW, Defendants Kopper Funding Corporation and Nicolas M. Bazan and bring
this their motion for leave to file amended pleading attached as Exhibit “A” and would show for
good cause as follows:

1. Defendants would show that they have diligently attempted to obtain discovery
from this particular plaintiff for over 8 months. The Plaintiff has steadfastly refused to
answer the discovery even though they have reflected they have additional documents to
produce. As a result of Defendant Nicolas M. Bazan’s serious illness and the delays caused
by Hurricane Harvey on the judicial system in Harris County, the Defendants’ Motion to
Compel the Discovery responses was not able to be filed until January 2018. Defendants

obtained the first se…