Pennsylvania’s liberal rules concerning the amendment of pleadings aren’t so liberal in the context of complaints for confession of judgment. When filing a complaint in confession of judgment, if a mistake is made in calculating the amount of damages or the time period in which damages accrued, an attorney cannot rely upon Pa. R.C.P. 1033 to make corrections by amendment. So held the Pennsylvania Superior Court in TCPF Limited Partnership v. Skatell, 976 A. 2d 571 (Pa. Super. 2009).
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