COMMONWEALTH OF MASSACHUSETTS

MIDDLESEX, ss SUPERIOR COURT DEPARTMENT

OF THE TRIAL COURT

______________________________

Yong Li, )

   Plaintiff, )

v. ) CIVIL ACTION NO.     1881CV03670

Yanling (Rebecca) Zeng, )

____________________Defendant. )

PLAINTIFF’S MOTION FOR LEAVE TO FILE

AMENDED COMPLAINT

The Plaintiff, Yong Li, respectfully moves the Court, pursuant to Rule 15 of Civil Procedure, for leave to file an Amended Complaint, a copy of which is attached hereto. The new complaint maintains the count and allegations against the same defendant from the original complaint, but splits the defamation into Libel and Slander, and adds Negligence as count three.

WHEREFORE, plaintiff Yong Li respectfully requests that this honorable Court grant Plaintiff’s motion for leave to file the proposed amended complaint.

Respectfully submitted,

Yong Li

/s/_

Name: Yong Li (pro se)

...

Date: January  30, 2019

CERTIFICATE OF SERVICE

I hereby certify the a true copy of the above document was

served upon each party appearing defendant (or her attorney) on some day, by first class mail, and by email.

/s/ Yong Li (Pro Se)