What is the procedure for amending a complaint for personal injury

Your additional information helps, but not quite enough. Without actually seeing your complaint, it is almost impossible for us to diagnose the problem which makes it equally impossible to prescribe a fix. This said, it may be that you have failed to adequately plead duty. In general, lawyers don't pay medical bills for clients. In personal injury cases, lawyers do negotiate and satisfy liens for clients, and they also will assist a client in paying off medical bills which are related to the accident if they are asked. If you and your lawyer had an understanding that he or she was going to negotiate and/or pay your related medical expenses out of your recovery, your complaint needs to include the fact that the two of you reached this agreement, the fact that a bill was sent to the lawyer before the case settled, the fact that the lawyer didn't negotiate or pay the bill out of the recovery as promised, and the fact that you were damaged by having to pay the bill out of your pocket instead of the recovery. Let me be clear-- I don't know if this will fix the problem because I don't know enough about the entire situation. There are other potential legal problems with your claims which are outside the scope of your question. I know this is what you were trying to avoid, but the best advice that any of us can give to you if you want to make sure that the complaint sticks is to talk to a lawyer about it right away.