Reyes v. Yager Esthetics Estetica

Background

Yandy Reyes sued Yager Esthetics Estetica, Jeffrey S. Yager, and unidentified defendants. Reyes alleged that the defendants violated the Telephone Consumer Protection Act, a federal law governing certain unwanted telephone calls and text messages, based on 13 unsolicited text messages. Reyes also alleged a violation of New York General Business Law § 396-AA.

The court’s scheduling order set January 15, 2025, as the deadline for motions to add parties or amend the complaint. Reyes timely moved to add SolutionReach, Inc. as a defendant and to change the name of previously named Defendant NewBeauty to NewBeauty Media Group, LLC. The opinion notes that Reyes later reached a settlement with NewBeauty Media Group, LLC and voluntarily dismissed all claims against that entity. Yager Esthetics Estetica and Jeffrey S. Yager did not oppose the motion.

Legal standard

Under Federal Rule of Civil Procedure 15, a party generally needs the opposing parties’ consent or the court’s permission to amend a complaint after the initial amendment period. Rule 21 also permits a party to be added at any time on appropriate terms. The court explained that the same standard applies under both rules: permission should ordinarily be granted unless there is undue delay, bad faith, unfair prejudice to the opposing party, or futility, meaning the proposed amendment would not be legally viable.

Because Reyes filed the motion before the scheduling-order deadline, the court held that the more demanding “good cause” requirement under Rule 16 did not apply. The court instead applied the more permissive Rule 15 standard.

Court’s analysis

The court found no undue delay because Reyes filed the motion by the deadline. It found no allegations of bad faith and no undue prejudice, noting that the existing defendants did not oppose the amendment. The court also found that Reyes acted diligently: according to Reyes, Yager knew SolutionReach’s identity but disclosed it to Reyes on January 14, 2025, and Reyes filed the motion the next day.

The court further concluded that adding SolutionReach would not significantly delay the case because discovery remained in its early stages. Because the defendants did not oppose the proposed amendment, the court found no basis to conclude that adding SolutionReach would be futile or otherwise improper.

Disposition

The court granted Plaintiff’s motion for leave to file an amended complaint. The Clerk of Court was directed to terminate the motion at ECF No. 26. The opinion’s express analysis and ruling address adding SolutionReach, Inc.; it does not separately state a ruling on the requested name change for NewBeauty beyond the overall grant of the motion.