Mudge v. Bank of America

2014 DNH 117
CourtDistrict Court, D. New Hampshire
DecidedMay 27, 2014
Docket13-cv-421-JD
StatusPublished

This text of 2014 DNH 117 (Mudge v. Bank of America) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mudge v. Bank of America, 2014 DNH 117 (D.N.H. 2014).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

John J. Mudge, Jr. and Lisa Mudge

v. Civil No. 13-cv-421-JD Opinion No. 2014 DNH 117 Bank of America, N.A. and TD Bank, N.A.

O R D E R

John and Lisa Mudge brought suit in state court against Bank

of America, N.A. (“Bank of America”) and TD Bank, N.A. (“TD

Bank”), alleging claims that arose from the defendants’ conduct

in handling the Mudges’ mortgages and in attempting to foreclose

on their home. TD Bank removed the case to this court, and the

claims against TD Bank were subsequently dismissed. After the

deadline in the scheduling order for amending pleadings had

passed, the Mudges filed an amended complaint without seeking

leave of the court or Bank of America’s consent. Bank of America

moved to strike the amended complaint. The Mudges objected, and

subsequently filed a motion for leave to amend their complaint.

Bank of America objected to the motion for leave to amend.

Bank of America moved for leave to file a reply to the

Mudges’ objection to its motion to strike. The Mudges filed an

objection, in which they merely repeat the arguments in their

objection to the motion to strike. Bank of America’s motion for

leave to file a reply (document no. 42) is granted, and the reply

has been considered in deciding the motion to strike. Discussion

Sometime prior to 2009, John and Lisa Mudge entered into a

loan with Bank of America which was secured by a mortgage on the

Mudges’ home at 57 Sterling Avenue in Hooksett, New Hampshire.

At some point, the Mudges stopped making their monthly mortgage

payments. On October 21, 2011, the Mudges learned that a

foreclosure sale of their home was scheduled for December 6,

2011. On November 10, 2011, the Mudges filed a Petition to

Enjoin foreclosure in the Merrimack County Superior Court. The

superior court granted the Mudges’ petition.

Bank of America subsequently moved in the superior court to

vacate the injunction. The superior court granted the motion on

April 22, 2013, and the Mudges’ motion to reconsider the order

was denied on May 23, 2013.

The following day, May 24, 2013, the Mudges filed a “first

amended complaint” in the superior court, naming Bank of America

as the defendant. The amended complaint asserted three claims

against Bank of America: breach of contract, negligent

misrepresentation, and a violation of the Consumer Protection

Act. The superior court subsequently dismissed the Consumer

Protection Act claim.

On August 29, 2013, the Mudges filed a second amended

complaint in the superior court. The second amended complaint

included the same breach of contract and negligent

misrepresentation claims, and added a claim for breach of the

implied covenant of good faith and fair dealing against Bank of

2 America. In addition, the second amended complaint named TD Bank

as a defendant and asserted claims for breach of contract,

negligent misrepresentation, and breach of the implied covenant

of good faith and fair dealing against TD Bank.

TD Bank removed the case to this court and moved to dismiss

the claims against it. The court granted TD Bank’s motion to

dismiss on November 20, 2013, and denied the Mudges’ motion to

reconsider that order on January 10, 2014.

The Mudges and Bank of America submitted a proposed

discovery plan on January 21, 2014, which was approved by the

court on January 24, 2014 (“scheduling order”). The scheduling

order provides that the deadline for the Mudges to amend their

pleadings was February 15, 2014. In addition, the deadline for

the Mudges to join additional parties was February 15, 2014.1

On March 18, 2014, the Mudges filed a third amended

complaint.2 The third amended complaint named both Bank of

America and TD Bank as defendants, asserted the same claims

against each defendant as the second amended complaint, and added

a claim for unjust enrichment against Bank of America and a claim

1 The scheduling order also provides that the deadline for Bank of America to amend its pleadings or join a party was March 15, 2014. 2 The Mudges titled the complaint: “Second Amended Complaint for Damages.” The previous complaint, however, is also titled “Second Amended Complaint for Damages.” The records of the superior court show that this is the third time the Mudges have sought to amend their complaint. The court will refer to the proposed amended complaint that is the subject of this order as the “third amended complaint.”

3 for violation of several federal statutes against both Bank of

America and TD Bank.

Bank of America moved to strike the third amended complaint,

arguing that it was untimely because the deadline for the Mudges

to amend their pleadings was February 15, 2014. Bank of America

also argued that the complaint should be struck because the

Mudges failed to seek its consent or move for leave to amend.

The Mudges objected, arguing that the deadline for amending their

pleadings was March 15, 2014, which fell on a Saturday. They

argued that they filed their amended complaint on the following

Tuesday, March 18, 2014, early in the morning, and suggested

that, therefore, the court should consider their amended

complaint timely under the scheduling order. They further argued

that Bank of America was aware that they would be amending the

complaint.

In its reply, Bank of America argued that the deadline for

the Mudges to amend their pleadings was February 15, 2014, not

March 15, 2014, but that regardless, the third amended complaint

was untimely under either deadline. Bank of America also argued

that it was unaware that the Mudges were going to amend their

On April 15, 2014, while Bank of America’s motion to strike

was pending, the parties filed summary judgment motions in

accordance with the deadline set forth in the scheduling order.

A few weeks later, on May 9, 2014, the Mudges filed a motion for

4 leave to file an amended complaint.3 In their motion for leave

to amend, the Mudges argued that Bank of America would not be

prejudiced because “the claims and basic facts in this case have

not changed.” Bank of America objects to the motion for leave to

amend, arguing that the motion is untimely, that the Mudges have

already amended their complaint twice, and that Bank of America

would be prejudiced by an amendment to the complaint because the

parties have already filed summary judgment motions.

I. Motion to Strike

“A party may amend its pleading once as a matter of course

within: (A) 21 days after serving it, or (B) if the pleading is

one to which a responsive pleading is required, 21 days after

service of a responsive pleading or 21 days after service of a

motion under Rule 12(b), (e), or (f), whichever is earlier.”

Fed. R. Civ. P. 15(a)(1). All other amendments require either

the opposing party’s consent or leave of court. See Fed. R. Civ.

P. 15(a)(2). When a plaintiff seeks to amend the complaint after

the scheduling order deadline, the plaintiff also must show good

cause to modify the scheduling order. Fed. R. Civ. P. 16(b)(4).

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