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101 that the Mazars Subpoena aims at advancing the goals of Congressional Democrats, and more. It is hard to see how the SAC could adequately be amended to cure these defects. If the President could cite new factual allegations that would remedy all of the defects highlighted above mere weeks after filing the SAC, the Court would be hard pressed to understand why they could not have been alleged in the SAC, particularly considering that the law on overbreadth and bad faith in the grand jury subpoena context is well-developed in New York. See Bui, 594 F. Supp. 2d at 373 (dismissing with prejudice a complaint that inadequately plead claims governed by “well-established” law). Such circumstances might suggest dilatory motive, which would present another apparent reason to deny leave to amend. See Krupski v. Costa Crociere S.p.A., 560 U.S. 538, 553 (2010) (noting “that a court may consider a movant’s ‘undue delay’ or ‘dilatory motive’ in deciding whether to grant leave to amend under” Rule...