A Pennsylvania federal district court denied a motion for leave to file a second amended complaint from a clerk with chronic migraines alleging disability discrimination, retaliation, and failure-to-accommodate claims under the Americans with Disabilities Act and Pennsylvania Human Relations Act against Cumberland County, finding that amending the complaint would be futile because the claims would be time-barred, that the clerk had unduly delayed seeking amendment for 19 months, and that the drastic factual changes would prejudice Cumberland County by requiring it to essentially re-litigate the case.
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