Second Circuit -- Williams v. Citigroup

Williams v. Citigroup

No obligation to file a motion to amend the pleadings with initial answer or prior to entry of judgment on a 12(b)6 - a postjudgment motion to that effect should be granted where amendment can cure the defects of the pleading.  

(Reasons - FRCP directive on liberal granting of leave to amend & desire of courts to answer questions on the merits. )