Much of this opinion is devoted to the humdrum details of default judgments. The District Court, however, also addressed the impact of an amended complaint on a prior default judgment. In this case, the District Court entered a default judgment against the corporate defendant, Green Energy Resources, Inc., after an extended period passed without its securing counsel. Slip op. at 2-4. The Freilich’s then sought to amend their complaint to add an alter ego theory against the individual defendants. Id. at 4, 8-9. The District Court pointed out that “courts routinely set aside entries of defaults when plaintiffs file amended complaints.” Id. at 14 (citing Rossignol v. Tillman, No. 10-3044, 2011 WL 1193017, at *2 (E.D. La. Mar. 25, 2011)). When the Freilich’s flinched at the prospect of losing their default judgment, the District Court denied the motion to amend without prejudice. Id. at 15.
