RULE 21 | MISJOINDER AND NONJOINDER OF PARTIES

"Motions to add parties are governed by Fed. R. Civ. P. 21 and are evaluated under the "same standard of liberality afforded to motions to amend pleadings under Rule 15." Addison v. Reitman Blacktop, Inc., 283 F.R.D. 74, 79 (E.D.N.Y. 2011); see Amaya, 285 F.R.D. at 253 ("There is... little practical difference between Rule 15 and Rule 21 since they both leave the decision whether to permit or deny an amendment to the district court's discretion.")."