United States District Court, D. New Jersey
OPINION AND ORDER
B. CLARK, III United States Magistrate Judge
MATTER comes before the Court on a motion by
Plaintiff Amjad Saiyed (“Plaintiff”) for leave to
file an Amended Complaint [ECF No. 144]. Defendants Rashid
Patel and Mohammed Ashif Gajra (“Defendants”)
opposes Plaintiff's motion [ECF. Nos. 163, 166, 167]. For
the reasons set forth below, Plaintiff's motion to amend
his Complaint [ECF. No. 144] is GRANTED.
BACKGROUND AND PROCEDURAL HISTORY
initiated this action by filing his Complaint in the United
States District Court for the Eastern District of New York
(“EDNY”) on November 21, 2014. See
Compl., ECF No. 1 (“Complaint”). Essentially,
Plaintiff's Complaint alleges that Defendants refused to
pay him minimum wages and “engaged in systematic
mistreatment of Plaintiff.” See Compl.
¶¶ 52-57. Plaintiff asserts eight causes of action
including, inter alia, one claim for failure to pay
proper wages under the Fair Labor Standards Act [Compl.
¶¶ 105-15], and three claims for failure to pay
proper wages under the New York Labor Law [Compl.
September 13, 2016, Plaintiff filed a motion to amend his
Complaint in the EDNY [ECF No. 119]. Shortly afterwards, and
before Plaintiff's motion to amend could be decided, this
matter was transferred to the District of New Jersey by the
Honorable Judge Joanne Seybert. See ECF No. 137. The
Court held a conference call with the parties on March 20,
2017 and the Court issued an Order granting Plaintiff leave
to file a motion to amend his Complaint [ECF No. 143].
Plaintiff filed said motion on March 24, 2017 [ECF No. 144]
and Defendants filed their opposition [ECF. Nos. 163, 166,
proposed amendments include additional claims for violation
of New Jersey's Wage and Hours laws arising out of
Defendants' alleged failure to pay Plaintiff wages owed
to him while working for Archon, Inc. and Archon
Rule of Civil Procedure 15(a) governs requests for leave to
amend, allowing a party to amend its pleadings after
obtaining the Court's leave or the written consent of its
adversary. Under this liberal rule, the Court must
“freely give leave when justice so requires.”
Fed.R.Civ.P. 15(a)(2); see also Wright & Miller section
1484, at 676 (“Subdivision (a)(2) encourages the court
to look favorably on requests to amend.”). This lenient
standard ensures that “a particular claim will be
decided on the merits rather than on technicalities.”
Dole v. Arco Chem. Co., 921 F.2d 484, 487 (3d
Cir.1990) (internal citation omitted); see also Sabatino
v. Union Township, No., 2013 WL 1622306, at *6 (D.N.J.
April 15, 2013) (internal citations omitted) (discussing that
“if the underlying facts relied upon by a party might
be a proper subject of relief, that party should have the
opportunity to test its claims on the merits.”).
decision to grant or deny leave to amend under Rule 15(a) is
“committed to the sound discretion of the district
court.” Arab African Int'l Bank v.
Epstein, 10 F.3d 168, 174 (3d Cir.1993). While courts
have broad discretion to decide motions to amend, they must
“heed Rule 15(a)'s mandate that amendments are to
be granted freely in the interests of justice.”
Voilas et al. v. General Motors Corp., et al, 173
F.R.D. 389, 396 (D.N.J.1997) (internal citations and
quotations omitted). In the absence of unfair prejudice,
futility of amendment, undue delay, bad faith, or dilatory
motive, the court must grant a request for leave to amend.
Grayson v. Mayview State Hosp., 292 F.3d 103, 108
(3d Cir.2002); see also Arthur v. Maersk, Inc., 434
F.3d 196, 204 (3d Cir.2006) (stating that generally, leave to
amend should be granted “unless equitable
considerations render it otherwise unjust.”).
in claims for unpaid wages, unpaid overtime compensation, or
other damages, New Jersey imposes a two-year statute of
limitations from the commencement of an action for recovery.
N.J. Stat. Ann. § 34:11-56a25.1 (West). However,
“[w]here an amendment relates back, Rule 15(c) allows a
plaintiff to sidestep an otherwise-applicable statute of
limitations, thereby permitting resolution of a claim on the
merits, as opposed to a technicality.” Id.
Furthermore, “Rule 15(c) endeavors to preserve the
important policies served by the statute of limitations-most
notably, protection against the prejudice of having to defend
against a stale claim, as well as society's general
interest in security and stability-by requiring ‘that
the already commenced action sufficiently embraces the
amended claims.' “Id. (quoting Nelson
v. Cnty. of Allegheny, 60 F.3d 1010, 1014-15 (3d
Federal Rule of Civil Procedure 15(c)(1)(B), “[a]n
amendment to a pleading relates back to the date of the
original pleading when the amendment asserts a claim or
defense that arose out of the conduct, transaction, or
occurrence set out-or attempted to be set out-in the original
pleading.” Fed.R.Civ.P. 15(c)(1)(B). Consequently,
“it is well-established that the touchstone for
relation back is fair notice, because Rule 15(c) is premised
on the theory that ‘a party who has been notified of
litigation concerning a particular occurrence has been given
all the notice that statutes of limitations were intended to
provide.'” Glover, 698 F.3d at 146
(quoting Baldwin Cty. Welcome Ctr. v. Brown, 466
U.S. 147, 149 n. 3, 104 S.Ct. 1723, 80 L.Ed.2d 196 (1984)).
As a result, “only where the opposing party is given
‘fair notice of the general fact situation and the
legal theory upon which the amending party proceeds' will
relation back be allowed.” Glover, 698 F.3d at
146 (quoting Bensel v. Allied Pilots Ass'n, 387
F.3d 298, 310 (3d Cir.2004)). Alternatively,
“amendments that significantly alter the nature of a
proceeding by injecting new and unanticipated claims are
treated far more cautiously.” Glover, 698 F.3d
at 146 (internal citation and quotations omitted).
claim that they would be prejudiced by Plaintiff's
proposed amendments because the parties have already began
conducting depositions, and the parties will likely need
additional discovery which will be timely and costly.
Def.s' Br. Opp'n ¶ 5, ECF No. 163-1.
Court finds Defendants' argument unpersuasive. Although
the parties have begun conducting depositions, discovery
remains open and the parties are expected to continue to use
the tools of discovery to obtain evidence in support of their
case. Furthermore, Plaintiff's proposed amendments will
not require ...