The following excerpt is from Fresno Rock Taco, LLC v. Nat'l Sur. Corp., CASE No. 1:11-cv-00845-SKO (E.D. Cal. 2013):
The party moving for a modification of a pretrial order has the burden of showing that an amendment is necessary to prevent manifest injustice. Galdamez v. Potter, 415 F.3d 1015, 1020
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