and will become ‘prejudicial,’ placing an unfair burden on the opposing party.” Delay may become undue when a movant has had previous opportunities to amend a complaint. Cureton, 252 F.3d at 273 (quoting Adams, 739 F.2d at 868) (internal citations omitted); see also Arthur v. Maersk, Inc., 434 F.3d 196, 205 (3d Cir.2006) (“There is, of course, no presumptive period in which a motion for leave to amend is deemed timely or in which delay becomes undue.”) (internal quotations omitted). Under this standard, courts have denied leave to amend following a three year lapse between the filing of the complaint and the proposed amendment, Lorenz v. CSX Corp., 1 F.3d 1406, 1414 (3d Cir.1993), and when the applicable party proposed a second amendment that essentially would “re 96 (8th Cir.2001) (<HOLDING>). Courts also have allowed amendment after
holding that denial of leave to amend is error in the absence of justifying reasons holding that denial of a postconviction motion without prejudice and with leave to amend is not a final appealable order holding that delay of eleven months did not justify denial of leave to amend holding that court may refuse leave to amend because of undue delay holding that the district court abused its discretion in denying leave to amend after a delay of eight months