Does the relation-back doctrine apply to add a new defendant after the statute of limitations has run?

MultiRegion, United States of America

The following excerpt is from Hall v. Kraft Heinz Food Co., 1:19-cv-00565-LJO-BAM (E.D. Cal. 2019):

In Williams v. Gyrus ACMI LP, No. 14-cv-00805-BLF, 2014 WL 4771667, at *4-5 (N.D. Cal. Sep. 24, 2014), the court explained that in order for a plaintiff to use the relation-back doctrine to add a new defendant after the statute of limitations has run, the plaintiff has the burden to show that the new defendant knew or should have known that the action would be brought against it, "but for a mistake

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