his FMLA rights. To do so, Periy would have to show (i) that he exercised an FMLA protected right; (ii) that he suffered an adverse employment action; and (iii) that there is a causal connection between the first two elements. See, e.g., Nichols v. Ashland Hosp. Corp., 251 F.3d 496 (4th Cir.2001). 4 . Additionally, American points to no specific prejudice it would suffer if Perry’s motion for leave to amend is granted. Its conclusory statements regarding prejudice are insufficient to bar Perry's motion for leave to amend. See, e.g., Spell v. McDaniel, 591 F.Supp. 1090, 1098 (E.D.N.C.1984) (generalized statements that defendant would suffer prejudice if leave to amend were granted deemed insufficient). 5 . See also In re Lease Oil Antitrust Litigation, 200 F.3d 317, 321 (5th Cir.2000) (<HOLDING>); Restatement (Second) of Judgments, § 25 cmt.
holding state immune from suit brought in state court holding that a federal court litigant who is forced into state court under pullman may reserve a right to return to federal court in that the plaintiff can preserve the right to the federal forum for federal claims by informing the state court of his or her intention to return following litigation of the state claims in the state court holding that state court judgment settling shareholders state and federal claims had preclusive effect in federal court even though shareholders could not have pressed their federal claims in state court holding that earlier state court litigation did not bar assertion of antitrust claims in a later federal suit since the antitrust claims could not have been brought in state court holding that even though  24 only refers to actions in state court it applies to state claims brought in federal court