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Saiyed v. Archon, Inc.

United States District Court, D. New Jersey

October 30, 2017

AMJAD SAIYED, Plaintiff,
v.
ARCHON, INC. et al., Defendant.

          OPINION AND ORDER

          JAMES B. CLARK, III United States Magistrate Judge

         THIS 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.

         I. BACKGROUND AND PROCEDURAL HISTORY

         Plaintiff 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. ¶¶ 116-34].

         On 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, 167].[1]

         Plaintiff's 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 Distribution, Inc.

         II. LEGAL STANDARD

         Federal 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.”).

         The 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.”).

         Additionally, 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 Cir.1995)).

         Under 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).

         III. DISCUSSION

         Defendants 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.

         The 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 ...


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