Plaintiff QS Holdco, Inc. respectfully submits this Memorandum of Law in support of its motion pursuant to Rules 59(e) and 60 of the Federal Rules of Civil Procedure (the “Rules”) (1) to vacate the judgment dated August 7, 2019 [Dkt. No. 103] (“Judgment”) dismissing Plaintiff’s case and allow Plaintiff to file an amended complaint to address the issues raised in the Opinion and Order dated August 6, 2019 [Dkt. No. 102] (“Opinion”), or (2) in the alternative, to modify the Judgment so as to dismiss Plaintiff’s claims under New York law without prejudice. A copy of Plaintiff’s proposed amended complaint (“Proposed Amended Complaint”) is being filed with this motion.
Here a link to documents with background on the case: https://finadium.com/judge-dismisses-qs-holdco-lawsuit-against-prime-brokers-based-on-claim-ownership/