Pursuant to Rule 52.04(a) of the Missouri Rules of Civil Procedure, [Party] respectfully moves this Court to enter its order requiring the joinder of [Name] as a party to this action, on the grounds that [Name] is an indispensable party herein so that a just adjudication of this matter cannot be made without such joinder, in that [Specify grounds]. Disposition of this action in the absence of [Name] may leave the [Party] subject to a substantial risk of incurring double, multiple, or otherwise inconsistent obligations by reason of his claimed interest.

 

Rule 55.33(d) Form 1. Motion and Notice of Motion for Leave to File Supplemental Petition 

[Caption]

To:

[Attorney for Defendant] 

 

[Address]

 

PLEASE TAKE NOTICE, that the plaintiff will move the Circuit Court for [County] to enter its order permitting [him/her/its] to file [his/her/its] supplemental petition, a copy of which is attached hereto, at [Time] on [Date], or as soon thereafter as counsel can be heard.

 

 

 

55.06. Joinder of Claims and Remedies



(a) Joinder of Claims. A party asserting a claim to relief as an original claim, counterclaim, cross-claim, or third-party claim may join, either as independent or as alternate claims, as many claims, legal or equitable, as the party has against an opposing party.



(b) Joinder of Remedies; Fraudulent Conveyances. Whenever a claim is one heretofore cognizable only after another claim has been prosecuted to a conclusion, the two claims may be joined in a single action; but the court shall grant relief in that action only in accordance with the relative substantive rights of the parties. For example, a plaintiff may state a claim for money and a claim to have set aside a conveyance fraudulent as to him, without first having obtained a judgment establishing the claim for money.