Abdell v. City of New York, 759 F. Supp. 2d 450

127 protesters/arrested at RNC mass arrest in NYC on Aug. 31, 2004
Galati announced march start and participated in arrest decision with Monahan
Plaintiffs sued City, Bloomberg, Kelly, Monahan and officers; Galati initially not named
Abdell I denied adding Galati for state claims due to statute of limitations
Krupski (2010) clarified relation-back standard under Rule 15(c)(1)(C); timing and notice become key

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Krupski permits relation back for lack of knowledge	Galati lacked knowledge of liability but knew of existence	Krupski narrowly limits to misidentification, not lack of liability knowledge	Yes; Krupski permits relation back in this context
Whether Galati received timely notice within the limitations period	Galati had actual notice via deposition, shared counsel	Notice not proven; needs more than contemporaneous representation	Yes; Galati had timely notice within 120 days
Whether Galati's belief his omission was a mistake was reasonable	Plaintiffs had reason to think omission was an error, not deliberate	Galati believed omission was strategic or voluntary	No; Galati could not reasonably believe omission was a mistake
Whether amendment to add Galati should be granted under Rule 15(c)(1)	Relation back appropriate due to Krupski and notice	Policy considerations or prejudice weigh against amendment	GRANTED; amendment allowed under Rule 15(c)(1) per Krupski

Krupski v. Costa Crociere S.p.A., 130 S. Ct. 2485 (2010) (relation back depends on what added party knew or should have known)
Capitol Records, Inc. v. Naxos of Am., Inc., 262 F. Supp. 2d 204 (S.D.N.Y. 2003) (constructive notice may be imputed through attorney for co-defendants)
Nelson v. Unum Life Ins. Co. of America, 468 F.3d 117 (2d Cir. 2006) (final judgment rule and collateral order principles)
Kahn v. Chase Manhattan Bank, N.A., 91 F.3d 385 (2d Cir. 1996) (collateral order doctrine and final judgment concept)