Barbara Fox and Joanne Nachio, of our Miami office, successfully opposed Plaintiff’s Motion for Leave to Amend Plaintiff’s Complaint, which led to a global settlement in a first-party property case for significantly less than the $150,000.00 proposal for settlement.  Suit was initially brought for breach of contract for payment related to a roof leak.   On the eve of trial, Plaintiff sought to amend the complaint to add over $100,000 in additional damages claiming they were an “ensuing loss.”  Barbara and Joanne masterfully created an Opposition to Plaintiff’s Motion, which clearly persuaded the Judge who denied Plaintiff’s motion to amend and told her attorney, “this is a new loss, so go file a new suit.” After the hearing, and in anticipation of the Motions in Limine that were filed, Plaintiff settled the case globally for $50,000.00.