Sharma v. Sapper, 5:21-ct-03311-M

Plaintiff Siddhanth Sharma filed multiple motions in No. 5:21-CT-3311-M, including motions to stay, to amend (two separate motions), to exceed word count, to reopen discovery, for reconsideration, and to seal (D.E. 70, 73, 86, 88).
Several defendants (John Sapper, Casandra Skinner Hoekstra, TextBehind, LLC, and NC Board of Elections) were previously dismissed by court order (Feb. 11, 2022); Sharma sought reconsideration as to TextBehind.
The court granted plaintiff’s motions to exceed the word count and denied the motion to seal (finding no confidential material), though it directed the clerk to maintain D.E. 88 as a proposed sealed document (which the court will not consider).
Sharma’s first motion to amend sought to add parties; the court found the proposed claims did not satisfy permissive-joinder requirements under Rule 20 and denied joinder as inappropriate.
Discovery closed on February 6, 2023; Sharma filed his second motion to amend on June 20, 2023, well past the 30-day post-discovery motion deadline. The court denied the second motion to amend and request to reopen discovery as untimely under Local Rule 7.1(a) and Rule 16(b).
Plaintiff’s motion for reconsideration of dismissal of TextBehind was denied under the interlocutory-reconsideration standard (no new evidence, change in law, or clear error producing manifest injustice).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Motion to exceed word count	Needs extended pages to present arguments	Not specifically contested	Granted
Motions to stay proceedings	Stay pending resolution of Sharma v. Buffaloe and the first motion to amend	Related case already dismissed; stay unnecessary	Denied as moot
First motion to amend — add parties (permissive joinder)	Leave to amend under Rule 15; proposed parties/claims belong in this action	Proposed claims are factually distinct; fail Rule 20 joinder requirements	Denied — permissive joinder not satisfied/futile
Second motion to amend & reopen discovery	Seeks additional amendment and discovery after extended briefing	Motion filed well after discovery closed and deadline; no good cause shown	Denied as untimely under Local Rule 7.1(a) and Rule 16(b) (lack diligence)
Motion for reconsideration (TextBehind dismissal)	Asks court to revisit dismissal of TextBehind, LLC	Prior order was correct; no intervening change or new evidence	Denied — no basis under interlocutory-reconsideration standards
Motion to seal (D.E. 88)	Seeks sealing and provides extended arguments	Document lacks confidential material and public access standard not met	Denied; D.E. 88 maintained as proposed sealed document and not considered

Laber v. Harvey, 438 F.3d 404 (4th Cir. 2006) (leave to amend should be freely granted absent prejudice, bad faith, or futility)
Hinson v. Norwest Fin. S.C., Inc., 239 F.3d 611 (4th Cir. 2001) (Rule 20 joinder requirements and §1367 jurisdictional considerations)
Aleman v. Chugach Support Servs., Inc., 485 F.3d 206 (4th Cir. 2007) (purpose and limits of permissive joinder under Rule 20)
George v. Smith, 507 F.3d 605 (7th Cir. 2007) (discussing improper joinder of unrelated claims)
Coughlin v. Rogers, 130 F.3d 1348 (9th Cir. 1997) (critique of multi-claim joinder where claims are factually unrelated)
Stonecrest Partners, LLC v. Bank of Hampton Roads, 770 F. Supp. 2d 778 (E.D.N.C. 2011) (Rule 16(b) good-cause/diligence focus for modifying scheduling orders)
Montgomery v. Anne Arundel County, [citation="182 F. App'x 156"] (4th Cir. 2006) (Rule 16(b) good-cause requires diligence)
United States v. Godwin, 247 F.R.D. 503 (E.D.N.C. 2007) (movant must justify tardiness to depart from scheduling order)
American Canoe Ass'n v. Murphy Farms, Inc., 326 F.3d 505 (4th Cir. 2003) (standards for reconsideration of interlocutory orders)
Carlson v. Boston Scientific Corp., 856 F.3d 320 (4th Cir. 2017) (reaffirming bases for revising interlocutory orders)
Doe v. Public Citizen, 749 F.3d 246 (4th Cir. 2014) (standard for sealing court records and weighing public access)