The following excerpt is from Lindauer v. Rogers, 91 F.3d 1355 (9th Cir. 1996):
While not rejecting this rule, we have not specifically held that a judgment must be reopened before a Rule 15(a) motion is considered. In Jarvis v. Regan, 833 F.2d 149 (9th Cir.1987) we stated:
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