Law Offices of Crystal Maroney, P.C. v. CFPB

Law Offices of Crystal Maroney, P.C. v. CFPB

Opinion

Pursuant to Southern District of New York Local Rule 7.1(d) and your Individual Rules of Practice I(B)-(C) and II(A), Plaintiff-Respondent Law Offices of Crystal Moroney, P.C. respectfully requests a pre-motion conference so that Plaintiff-Respondent may move for an order to consolidate Law Offices of Crystal Moroney, P.C. v. CFPB et al., Case No. 7:19-cv-11594 with CFPB v. Law Offices of Costal Moroney, P.C. Case No. 7:20-cv-3240, [*2]  pursuant to Federal R. Civ. P. 42(a), and to stay both cases until July 1, 2020, pursuant to this Court's inherent power to control the disposition of cases on its docket in an efficient manner. Plaintiff-Respondent has Sled this letter-motion through ECF and has marked Chambers' e-mail "URGENT," pursuant to Rule 3(B) of your Emergency Individual Rules and Practices in Light of COVID-19. Plaintiff-Respondent requests expedited consideration of this letter-motion to forestall additional unnecessary delay and needless costs in these two related cases.

Motion to Consolidate Proceedings

Plaintiff-Respondent intends to move to consolidate the proceedings. Under the Federal Rules of Civil Procedure, [i]f actions before the court involve a common question of law or fact, the court may: (1) join for hearing or trial any or all matters at issue in the actions; (2) consolidate the actions; or (3) issue any other orders to avoid unnecessary cost or delay." Fed. It Civ. P. 42(a). These cases have the same parties, the same operative facts, the same applicable law, the same venue, and even the same judge. Running two nearly identical cases on separate tracks is grossly inefficient.

The Bureau, however, is against consolidation, despite [*3]  affirmatively asserting that

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