Michael Bai, Dennis Dozis and local counsel successfully moved to dismiss a leading manufacturer of construction machinery and engines from an action pending in the United States District Court for the Eastern District of Michigan. The court accepted our argument that the plaintiff’s claims against the manufacturer were time-barred because the co-defendant named our client as a non-party at fault nearly one year after filing its initial pleading, in contravention of Michigan law, and plaintiff’s subsequent amendment of the complaint over one year after being placed on notice of the correct manufacturer was also untimely.