Unreported / Non-Citable
Background
Booster Fuels, Inc. sued Shweta Madasu in the U.S. District Court for the Southern District of California, Case No. 26-CV-3498 JLS (GC). The two-page order does not describe the claims in detail. It indicates that Plaintiff's allegations concern, at least in part, the downloading of certain documents by Defendant, and that Defendant had already filed an original answer responding to them.
The parties then filed a joint Stipulation to File First Amended Answer (ECF No. 13). Defendant stated in the stipulation that the proposed amendment rests on new information she could not have obtained with due diligence when she filed the original answer. That is a representation by the party, which the court recited but did not separately find to be true. Plaintiff joined the stipulation, so the court was not resolving a contested motion.
The proposed First Amended Answer, attached to the stipulation as ECF No. 13-1, adds more specific admissions and denials responding to Plaintiff's allegations. In the court's example, Defendant admits downloading certain documents but denies that she did so for an improper purpose. Those are a party's pleaded positions, not findings by the court about what actually happened or why.
The Court’s Holding
Judge Janis L. Sammartino approved the stipulation under Federal Rule of Civil Procedure 15(a)(2), which directs courts to freely grant leave to amend when justice so requires. Citing Eminence Capital, LLC v. Aspeon, Inc., 316 F.3d 1048 (9th Cir. 2003) (per curiam), the court noted that this policy is applied with extreme liberality. It also noted that, absent prejudice or a strong showing on any remaining factor, a presumption favors leave to amend. The court recited the factors from Foman v. Davis, 371 U.S. 178, 182 (1962): undue delay, bad faith or dilatory motive, repeated failure to cure deficiencies through earlier amendments, undue prejudice to the opposing party, and futility.
Applying those principles, the court found that the proposed amendments will clarify the disputed facts and aid in resolving the matter. It observed that Defendant has not previously sought to amend her original answer, that Plaintiff joined the stipulation, and that there is no evidence that any of the remaining Foman factors apply. The court made no further, separate findings on delay, bad faith, or futility, and it did not test Defendant's due-diligence explanation.
The disposition is an order, not a recommendation. Finding good cause, the court approved the stipulation and directed Defendant to file her amended answer within five days of the date the order is electronically docketed. The order resolves only this pleading question. It does not decide any claim or defense, does not rule on whether the downloading was improper, and does not end the case, which remains pending.
Key Takeaways
- A stipulated request to amend an answer is evaluated under Rule 15(a)(2), and Ninth Circuit authority applies that rule with extreme liberality.
- The court relied on three specific points: the amendment clarifies disputed facts, Defendant had not amended before, and Plaintiff joined the stipulation.
- Absent prejudice or a strong showing on another Foman factor, the Ninth Circuit presumption favors granting leave to amend.
- The court did not separately verify Defendant's statement that the new information could not have been obtained earlier with due diligence. It relied on the absence of evidence of any adverse Foman factor.
- The order sets a short deadline: the amended answer must be filed within five days after the order is electronically docketed.
Why It Matters
The order is a routine case-management ruling. It is not a reported opinion and carries no precedential weight beyond this case. Its value lies in showing how a Southern District of California judge documents a Rule 15(a)(2) analysis even when the parties agree, tying the stipulated amendment to the Foman factors rather than simply signing it.
For practitioners, the order shows what a stipulation should provide: a short explanation of why the amendment is needed, a proposed pleading attached for the court's review, and the opposing party's express agreement. The attached pleading let the court see concretely how the answer would change, namely through more specific admissions and denials. Because the order does not address the merits, readers should not treat the admission-with-denial example as any signal of how the court views the document-downloading allegations. Everything on the merits remains open, including whether Plaintiff can prove its claims and whether Defendant's denial of improper purpose holds up.