The following excerpt is from Krasnoff v. Lancaster Baptist Church (In re Rosen), Adv. No.: 2:17-ap-01491-ER, Case No.: 2:16-bk-24731-ER (Bankr. C.D. Cal. 2018):
undue delay, (2) bad faith or dilatory motive, (3) futility of amendment, and (4) prejudice to the opposing party. See Foman v. Davis, 371 U.S. 178, 182 (1962).
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