Judge: Thomas D. Long, Case: 23STCV04727, Date: 2023-11-07 Tentative Ruling

Case Number: 23STCV04727    Hearing Date: November 7, 2023    Dept: 48

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT

On March 3, 2023, JPMorgan filed this interpleader action against Keith W. Furlong, David J. Parsons, Golden Eagle Aviation Group Inc., and Karena P. Chuang.

On March 23, 2023, JPMorgan filed a Notice of Related Case, identifying Case No. 18STCP02593 (where judgment was previously entered) as related.  The Court later related the cases.

On October 2, 2023, Furlong and Parsons moved to consolidate this action with Case No. 23STCV14344.  JPMorgan filed a Notice of Non-Opposition.

“When actions involving a common question of law or fact are pending before the court, it may order a joint hearing or trial of any or all the matters in issue in the actions; it may order all the actions consolidated and it may make such orders concerning proceedings therein as may tend to avoid unnecessary costs or delay.”  (Code Civ. Proc. § 1048, subd. (a).)  The purpose of consolidation is to enhance trial court efficiency by avoiding unnecessary duplication of evidence and the danger of inconsistent adjudications.  (See Todd-Stenberg v. Dalkon Shield Claimants Trust (1996) 48 Cal.App.4th 976, 978-979.)

Under Los Angeles Superior Court Rule 3.3, subdivision (g), “A motion to consolidate two or more cases may be noticed and heard after the cases, initially filed in different departments, have been related into a single department, or if the cases were already assigned to that department.”

Case No. 18STCP02593 and Case No. 23STCV14344 are already related.  This case has been related with Case No. 18STCP02593, but not with Case No. 23STCV14344 (nor has a Notice of Related Case been filed for that case).

Accordingly, on its own motion the Court finds that Case Nos. 18STCP02593, 23STCV04727, and 23STCV14344 are related within the meaning of California Rules of Court, rule 3.300(a).

With respect to consolidation, this case and Case No. 23STCV14344 both have the same $303,383.64 at issue.  Case No. 23STCV14344 alleges withholding and fraudulent conveyance of funds that belong to Furlong and Parsons.  In this action, JPMorgan asks that the Interpleader Defendants be ordered to interplead and litigate their respective rights to those funds, which are being held by JPMorgan pursuant to a notice of levy.

No oppositions were filed, and JPMorgan specifically stated that it does not oppose this motion.

Accordingly, the motion is GRANTED.  Case No. 23STCV04727 and Case No. 23STCV14344 are consolidated.  Case No. 23STCV04727 is the lead case, and all future pleadings must be filed under this case number.

Moving party to give notice.

Parties who intend to submit on this tentative must send an email to the Court at SMCDEPT48@lacourt.org indicating intention to submit.  If all parties in the case submit on the tentative ruling, no appearances before the Court are required unless a companion hearing (for example, a Case Management Conference) is also on calendar.

         Dated this 7th day of November 2023