California, United States of America
The following excerpt is from VillaSport, LLC v. Colo. Structures, Inc., A150372 (Cal. App. 2020):
9. This distinguishes Duchrow v. Forrest (2013) 215 Cal.App.4th 1359, where the amendment relied on a new theory of liability to more than triple the damages sought, and the court identified discovery that could have been pursued and an expert who could have been retained had the amendment been made in a timely way. (Id. at p. 1381.)
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