Halabi v. Mega Bank

CourtDistrict Court, S.D. Florida
DecidedSeptember 2, 2025
Docket1:25-cv-20902
StatusUnknown

This text of Halabi v. Mega Bank (Halabi v. Mega Bank) is published on Counsel Stack Legal Research, covering District Court, S.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Halabi v. Mega Bank, (S.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 25-CV-20902-BECERRA/TORRES CARMEN A. HALABI, et al., Plaintiffs, v. MEGA BANK, Defendant.

_________________________________________/ ORDER ON MOTION FOR LEAVE TO AMEND COMPLAINT This cause comes before the Court on Plaintiffs’ Motion for Leave to File a First Amended Complaint, and to file that First Amended Complaint under seal. [D.E. 53]. Defendants filed a response to the Motion [D.E. 55], to which Plaintiffs replied. [D.E. 56]. The Motion, therefore, is ripe for disposition. After careful review of the briefing

and relevant authorities, and for the reasons set forth below, Plaintiffs’ Motion is GRANTED in part and DENIED in part.1

1 On August 28, 2025, the Honorable Jacqueline Becerra referred this matter to the Undersigned Magistrate Judge for disposition. [D.E. 70]. I. BACKGROUND This case centers on an alleged fraudulent scheme launched against Plaintiffs and permitted and aided by Defendant, Mega Bank. Specifically, Plaintiffs allege that

a group of scammers wrongfully procured $950,000 of Plaintiffs’ money, and Defendant helped facilitate that scam. In the pending Motion, Plaintiffs seek to amend their Complaint, both to add the individual scammers as defendants and to add several claims. In their response, Defendant does not oppose the amendment request, nor does it disagree with Plaintiffs’ general right to amend the Complaint. Rather, Defendant

argues that the Court should first rule on Defendant’s pending motion to dismiss, because it (1) requests transfer, and (2) argues that the Court lacks jurisdiction. Defendant also requests that the Court proactively bar Plaintiffs from ever amending their Complaint again. II. APPLICABLE PRINCIPLES AND LAW

Federal Rule of Civil Procedure 15(a) governs amendments to pleadings. A party may amend any pleading once as a matter of right before a responsive pleading has been filed or within twenty-one (21) days after serving the pleading if no responsive pleading is allowed. See Fed. R. Civ. P. 15(a)(1). In all other situations, the amending party must obtain written consent from the opposing party or leave of the court to amend the pleading. See Fed. R. Civ. P. 15(a)(2). The rule declares that

leave to amend “shall be freely given when justice so requires.” Id. If the underlying facts or circumstances relied upon by a plaintiff may be a proper subject of relief, he ought to be afforded an opportunity to test his claim on the merits. See Foman v. Davis, 371 U.S. 178, 182 (1962). Any amendments leading to a modification of the required pretrial scheduling

order are subject to a “good cause standard of scrutiny.” See Fed. R. Civ. P. 16(b)(4). That means that, after the deadline for amending pleadings set forth in a scheduling order has passed, the party seeking the amendment must show good cause on why leave to amend the complaint should be granted. See, e.g., Ray v. Equifax Info. Servs., LLC, 2009 WL 977313, at *1 (11th Cir. 2009) (citing Sosa v. Airprint Sys., Inc., 133 F.3d 1417, 1419 (11th Cir. 1998)). A district court need not allow an amendment

where allowing the amendment would cause undue prejudice to the opposing party. See Bryant v. Dupree, 252 F.3d 1161, 1163 (11th Cir. 2001). Of course, the grant or denial of an opportunity to amend is within the discretion of the district court, but outright refusal to grant the leave without any justifying reason appearing for the denial is not an exercise of discretion; it is merely abuse of that discretion and inconsistent with the spirit of the Federal Rules. Id. In the absence of any apparent or declared reason the leave sought should, as the rules

require, be “freely given.” Id. Substantial reasons justifying a court’s denial of a request for leave to amend include undue delay, bad faith, or dilatory motive on the part of the movant, and repeated failure to cure deficiencies by amendments previously allowed. See, e.g., Well v. Xpedx, No. 8:05-2193-CIV, 2007 WL 1362717, at *1 (M.D. Fla. May 7, 2007) (citing Burger King Corp. v. Weaver, 169 F.3d 1310, 1319 (11th Cir. 1999)). Even when an amendment is sought as a result of new information obtained during discovery, it is not an abuse of discretion to deny leave to amend if the moving party unduly delays pursuit of the amended pleading. See, e.g., United States v.

$172,760 in U.S. Currency, No. 7:06-51-CIV, 2007 WL 1068138 (M.D. Ga. Apr. 5, 2007). Additionally, a district court may properly deny leave to amend when an amendment would be futile. See Hall v. United Ins. Co. of Am., 367 F.3d 1255, 1262– 263 (11th Cir. 2004); see also Eveillard v. Nationstar Mortg. LLC, No. 14-61786-CIV, 2015 WL 1191170, at *6 (S.D. Fla. Mar. 16, 2015) (“The law in this Circuit is clear that ‘a district court may properly deny leave to amend the complaint under Rule

15(a) when such amendment would be futile.’”) (quoting Hall, 367 F.3d at 1263). “When a district court denies the plaintiff leave to amend a complaint due to futility, the court is making the legal conclusion that the complaint, as amended, would necessarily fail.” St. Charles Foods, Inc. v. Am.’s Favorite Chicken Co., 198 F.3d 815, 822 (11th Cir. 1999). This determination is akin to a finding that the proposed amendment would not survive a motion to dismiss. See Christman v. Walsh, 416 F. App’x 841, 844 (11th Cir. 2011) (“A district court may deny leave to amend a

complaint if it concludes that the proposed amendment would be futile, meaning that the amended complaint would not survive a motion to dismiss.”). III. ANALYSIS We will first assess whether amendment should be permitted, and will then

address Plaintiffs’ motion to file under seal. A. Leave to Amend is Permitted Defendant does not oppose amendment. Rather, Defendant argues that its pending motion to dismiss should be decided before this Motion for Leave to Amend.

In its motion to dismiss, Defendant argues both that this case should be transferred to the Central District of California, and, relatedly, that the Court lacks personal jurisdiction over Defendant under Rule 12(b)(2). Consequently, because these issues could dispose of the case altogether, Defendant argues that these issues should be decided first. Plaintiffs, meanwhile, argue that jurisdiction and venue should not be decided

without supplemental briefing on the issue (for which Plaintiffs have sought leave to file), or without Plaintiffs’ proposed new allegations. To that end, Plaintiffs argue that recently-acquired discovery—which is incorporated in the allegations of Plaintiffs’ proposed First Amended Complaint—helps demonstrate the Court’s personal jurisdiction over Defendant. It further alleges Plaintiffs’ Florida domicile, which, in Plaintiffs’ view, undermines transfer. Thus, because the First Amended Complaint seeks to address the deficiencies identified in the pending motion to dismiss, Plaintiff

argues that amendment is appropriate.

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Related

Burger King Corp. v. Weaver
169 F.3d 1310 (Eleventh Circuit, 1999)
Odessa Dee Hall v. United Insurance Co. of America
367 F.3d 1255 (Eleventh Circuit, 2004)
Foman v. Davis
371 U.S. 178 (Supreme Court, 1962)
Federal Trade Commission v. Abbvie Products LLC
713 F.3d 54 (Eleventh Circuit, 2013)
Christman v. Walsh
416 F. App'x 841 (Eleventh Circuit, 2011)

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