Trammel
Trammel v. Sanofi S.A. LLC
Opinion
Trial Court Opinion
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
LINDA TRAMMEL, Case No. 23-cv-06001-VC
Plaintiff,
ORDER DENYING MOTION FOR
v. LEAVE TO AMEND COMPLAINT
SANOFI-AVENTIS U.S LLC, et al., Re: Dkt. No. 28 Defendants.
Trammel’s motion for leave to amend her complaint is denied. Trammel also seeks leave to file a late reply brief, which is granted. Trammel wishes to amend the definition of her injury and add allegations of fraudulent concealment, but the MDL court previously rejected similar efforts to amend the Master Complaint in 2019. Despite acknowledging the MDL court’s prior ruling, Trammel does not offer any argument as to why that ruling was erroneous or resulted in a manifest injustice. Because the MDL order is the law of the case, it will not be disturbed absent extraordinary circumstances. See Christianson v. Colt Industries Operating Corp., 486 U.S. 800, 817 (1988); White v. Novartis Pharmaceuticals Corp., No. CIV. 2:06-665 WBS GG, 2010 WL 3448589, at *2 (E.D. Cal. Sept. 1, 2010). Trammel’s request to amend also comes too late. After denying leave to amend the Master Complaint, the MDL court issued Pretrial Order…