SEPTA v. Orrstown Fin. Serv. Inc.

The Third Circuit provided civil procedure junkies with their fix when the Court detangled Rule 15(c) as well as statutes of limitations and repose. In this securities litigation, certain claims were dismissed early in the proceedings. After a lengthy period of discovery, the plaintiffs sought to amend their complaint to reinstitute the dismissed claims based on new evidence uncovered during discovery. But the repose period for those claims had already lapsed. The Third Circuit ruled that the amendments to the claims related back to the original claims, and neither the statutes of limitations nor repose barred the amendments.

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