Filed by Conrad · Case 26-104594-DO
33 Motion For Leave To Amend Counterclaim 2026-05-18
Canonical record: rockenhaus.net. Disputed domains are indexed at /disputed-domains/ (not authoritative).
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STATE OF MICHIGAN
IN THE THIRD JUDICIAL CIRCUIT FOR THE COUNTY OF WAYNE
FAMILY DIVISION, DOMESTIC RELATIONS
ADRIENNE MARJORIE ROCKENHAUS, Case No. 26-104594-DO
Plaintiff/Counter-Defendant,
Hon. Nicole N. Goodson
v.
CONRAD ALAN ROCKENHAUS,
Defendant/Counter-Plaintiff.
DEFENDANT/COUNTER-PLAINTIFF'S MOTION FOR LEAVE TO FILE FIRST
AMENDED COUNTERCLAIM
NOW COMES Defendant/Counter-Plaintiff Conrad Alan Rockenhaus, appearing pro se, and respectfully
moves this Honorable Court for leave to file his First Amended Counterclaim pursuant to MCR 2.118(A)(2).
In support of this motion, Counter-Plaintiff states as follows:
I. PROCEDURAL POSTURE
1. Counter-Plaintiff filed his Answer to Verified Complaint for Divorce, Affirmative Defenses, and
Counterclaim on April 15, 2026.
2. Counter-Defendant, through her counsel of record Aldrich Legal Services, PLLC, was served with the
Counterclaim on April 15, 2026.
3. Counter-Defendant failed to file a timely Answer to the Counterclaim. The Clerk of this Court entered
Default against Counter-Defendant on the Counterclaim on May 12, 2026 (MC07 entered same day).
4. Counter-Plaintiff filed his Motion for Default Judgment on Counterclaim pursuant to MCR 2.603(B)(3) on
May 12, 2026. The Motion is pending hearing date assignment by chambers.
5. The 14-day window for amendment as of right under MCR 2.118(A)(1) has closed. Amendment is
therefore sought by leave of Court under MCR 2.118(A)(2).
II. LEGAL STANDARD
6. MCR 2.118(A)(2) provides that, beyond the as-of-right window, "a party may amend a pleading only by
leave of the court or by written consent of the adverse party. Leave shall be freely given when justice so
requires."
7. Michigan appellate authority consistently interprets the "freely given when justice so requires" standard
liberally. Reasons that justify denial of leave are limited and include undue delay, bad faith, dilatory
motive on the part of the movant, repeated failure to cure deficiencies by amendments previously
allowed, undue prejudice to the opposing party, and futility. Weymers v Khera, 454 Mich 639, 658-659;
563 NW2d 647 (1997); Ben P Fyke & Sons, Inc v Gunter Co, 390 Mich 649, 656; 213 NW2d 134 (1973).
8. The mere fact that default has been entered does not preclude amendment. Default establishes liability
on the originally pleaded facts but does not lock the pleading against further evidentiary development of
the same claims. Wood v Detroit Auto Inter-Ins Exch, 413 Mich 573, 583; 321 NW2d 653 (1982) (default
operates as admission of well-pleaded facts but not as a bar to procedural development).
9. MCR 2.118(D) further provides that an amendment "relates back to the date of the original pleading"
where the amended claim "arose out of the conduct, transaction, or occurrence set forth, or attempted to
be set forth, in the original pleading." The relation-back doctrine applies here.
III. REASONS SUPPORTING AMENDMENT
10. Counter-Plaintiff's original Counterclaim, at §VI (¶¶34-43), described Counter-Defendant's coordinated
harassment of Counter-Plaintiff through online channels operating as Counter-Defendant's identity-
amplification network. The original Counterclaim identified Counter-Defendant's verified main account
@adezero and made allegations regarding her operation of sockpuppet accounts on the X/Twitter
platform.
11. Since the April 15, 2026 filing date, Counter-Plaintiff has developed substantial new documentary
evidence of the coordinated harassment operation that was alleged in general terms in the original
pleading. The new evidence does not assert new claims; it provides the documentary substrate for
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About this filing
33 Motion For Leave To Amend Counterclaim 2026-05-18: filing by Conrad Alan Rockenhaus in Rockenhaus v. Rockenhaus (Divorce), Michigan Case No. 26-104594-DO, Wayne County Circuit Court. PDF and searchable text at rockenhaus.net (canonical court record). Disputed third-party domains: /disputed-domains/.
- File name
33_Motion_for_Leave_to_Amend_Counterclaim_2026-05-18.pdf- Filed date
- Case number
- 26-104594-DO
- Category
- Filed by Conrad
- Disputed domains
- View disputed domains (asserted controlled by Adrienne Rockenhaus; not authoritative).
- Related context
- FAQ, Joe Prich evidence, Rob Hein
- Canonical record
- rockenhaus.net