Michael Guerrero successfully defended a motion to amend in a personal injury action. The motion to amend sought to add the driver involved in a motor vehicle accident as a named defendant in a lawsuit that had been pending since March 3, 2022. Michael successfully argued the motion was untimely and lacked evidence that the driver had notice of the lawsuit. Prevailing on the motion meant that the driver would not become a party to the lawsuit and capped the potential exposure of the owner of the vehicle.