退费追加被告申请书模板
    英文回答：
    Motion to Amend Complaint to Add Additional Defendant for Rescission.
    Court:
    Case Number:
    Moving Party:
    Responding Party:
    INTRODUCTION.
    The Moving Party, [Plaintiff's Name], respectfully requests that this Court amend its Complaint to add [Additional Defendant's Name] as an additional defendant in this action for rescission.
defendant    FACTS.
    The Moving Party and the original defendant, [Original Defendant's Name], entered into a contract for the purchase of [subject of contract]. The Moving Party alleges that the contract was induced by fraud and misrepresentation on the part of [Additional Defendant's Name].
    ARGUMENT.
    The Moving Party contends that [Additional Defendant's Name] is a necessary and proper party to this action for rescission. [Additional Defendant's Name] was directly involved in the transaction that led to the contract and is alleged to have made the fraudulent misrepresentations that induced the Moving Party to enter into the contract.
    The addition of [Additional Defendant's Name] as a party to this action will not prejudice [Original Defendant's Name] in any way. The claims against [Additional Defendant's Name] are based on the same facts and circumstances as the claims against [Original Defendant's Name].
    The amendment of the Complaint is necessary in order to provide the Moving Party with complete relief. If the Court denies the Motion, the Moving Party will be unable to recover its damages from [Additional Defendant's Name], who is jointly and severally liable for the fraud that induced the contract.
    CONCLUSION.
    WHEREFORE, the Moving Party respectfully requests that this Court grant its Motion to Amend Complaint to Add Additional Defendant for Rescission.
    ORDER.
    Based upon the foregoing Motion and supporting materials, IT IS HEREBY ORDERED that the Complaint in this action be amended to add [Additional Defendant's Name] as an additional defendant.

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