MOTION FOR LEAVE TO FILE SECOND AMENDED COMPLAINT

MOVING PARTY: Plaintiffs Chaorong Huang, Nanping Luo, Yuchun Wei and Wenhui Lin

RESPONDING PARTY(S): No opposition filed.

PROOF OF SERVICE:

ANALYSIS

Motion for Leave to File Second Amended Complaint

Plaintiff moves for leave to file a second amended complaint, eliminating five defendants and all federal law claim, and to add four new causes of action: (1) civil conspiracy to commit torts; (2) violation of the California Uniform Trade Secrets Act, Civil Code § 3426 et seq.; (3) Intrusion Into Private Affairs; and (4) Imposition of a Constructive Trust.

The court may, in furtherance of justice, and on such terms as may be proper, allow a party to amend any pleading. CCP 473(a)(1). Amendments of pleadings can be permitted up to and during trial, absent prejudice to the adverse party. Atkinson v. Elk Corp. (2003) 109 Cal.App.4th 739, 761. Judicial policy favors liberal exercise of the discretion to permit amendment of the pleadings.