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Can plaintiff amend his original claim and balance at summary judgement stage?

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If the original claim was initially based on a total of 54 statements, but later during the summary judgment stage, the plaintiff decides to amend it to include only 50 statements because they acknowledge that the last four were not sent to the defendant's registered address, could this raise concerns about fairness and transparency in the legal proceedings? What legal defenses might be available for the defendant in such a situation? Can the defendant compel the plaintiff to dismiss the case and file a new complaint? Is it necessary for the plaintiff to file a motion for leave to amend the complaint at the summary judgment stage? Are there any relevant case examples or legal defenses that the defendant could explore in similar situations? Greatly appreciate all help!


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