Emerald Site Services, Inc. v. Papé Machinery, Inc., et al.

Summary

The United States District Court for the Eastern District of California denied Emerald Site Services, Inc.’s motion for leave to file a second amended complaint. Applying Federal Rule of Civil Procedure 16(b)’s good-cause standard, the court found that Plaintiff lacked diligence in seeking to add two plaintiffs, a new defendant, allegations concerning a 2025 engine failure, and negligence claims after amendment and discovery deadlines had passed. The court also denied Plaintiff’s motion to strike the late opposition as moot.

Holdings

1. Plaintiff failed to establish good cause because plaintiff and counsel lacked diligence in investigating and presenting information about entities within plaintiff's own corporate relationship and then waited months after learning the information to seek amendment.
2. Plaintiff failed to establish good cause because, although the 2025 engine failure and its alleged cause were newly discovered, plaintiff waited more than two months to seek amendment after learning of them and did not seek expedited consideration despite the approaching deadlines and completed discovery.
3. The court disregarded the arguments in Papé's extremely late-filed opposition.

Questions Presented

1. Whether plaintiff established good cause under Federal Rule of Civil Procedure 16(b)(4) to modify the scheduling order and add Arctos Erosion Control, Inc. and Iron Poppy, Inc. as plaintiffs.
2. Whether plaintiff established good cause under Rule 16(b)(4) to add allegations concerning the April 2025 engine failure, add Finn Corporation, Inc. as a defendant, and assert new negligence claims.
3. Whether plaintiff's motion to strike defendants' late-filed opposition should be denied as moot.

Disposition

other