Epstein Secrets

o amend should not be given automatically." Chitimachia Tribe of Louisiana Harry L. Laws Co 690 F.2d 1157, 1163 (5th Cir. 1982), citin Addington'. Farmer's Elevator Mut. Ins. Co., 650 F.2d 663, 666 (5th Cir. 1981). The Fifth Circuit observed that the "[m]ere passage of time need not result in a denia

sed upon the statute of limitations, which was granted by the district court. As to the dismissal of Northern Counties, the appellate court rejected Northern Counties' argument that the amendment related back under Rule 15(c). The District of Columbia Circuit relied in part upon a Fifth Circuit case, Williams'. Un

d 1157, 1163 (91' Cir. 1982), citing Addington I. Farmer's Elevator Mut. Ins. Co., 650 F.2d 663, 666 (56'

sed upon the statute of limitations, which was granted by the district court. As to the dismissal of Northern Counties, the appellate court rejected Northern Counties' argument that the amendment related back under Rule 15(c). The District of Columbia Circuit relied in part upon a Fifth Circuit case, Williams I. U

1157, 1163 (5'1' Cir. 1982), citing Addington I. Farmer's Elevator Mutual Insurance maC ., 650 F.2d 663,

tially the same facts and theories as those in the earlier one." M. 1305-06. As to the dismissal of Northern Counties, the appellate court rejected Northern Counties' argument that the amendment related back under Rule 15(c). The District of Columbia Circuit relied in part upon a Fifth Circuit case, Williams I. U