Templete Motion for Consolidation of Claims

IN THE CIRCUIT COURT FOR BALTIMORE COUNTY, MARYLAND

STEVEN A. MANNING - Plaintiff
v
MARGARIA LASANTA - Defendant,

CASE NO. 13-C-02-053875

MOTION TO CONSOLIDATE

Steven A. Manning, Plaintiff, by his attorneys, Ronald V. Miller, Jr., Laura G. Zois, and Miller & Zois, LLC, moves pursuant to Maryland Rule 2-503(a) for a consolidation of Circuit Court for Baltimore County, Maryland, Case No.: 13-C-02-053875 with the instant case filed in the Circuit Court for Baltimore City this date, and for grounds therefor says:

  1. This case involves wrongful death traffic crash on August 26, 2016. Plaintiff filed suit against the driver, Margaria Lasanta, in Baltimore County on December 6, 2016. See Exhibit 1. Plaintiff has not yet been served and there has been no other activity in the case.
  2. On January 18, 2017, GEICO filed a motion to intervene in the case pending in Baltimore County. See Exhibit 2.
  3. Under Maryland Rule 2-503(a), consolidation is permitted when actions involve a common question of law or fact or a common subject matter.
  4. Plaintiff filed suit against GEICO in Baltimore City Circuit Court.
  5. GEICO habitually engages in regular business in Baltimore City.
  6. Plaintiff's counsel spoke this morning to Defendant's Margaria Lasanta's counsel. Defendant is not sure at this time whether she will contest Plaintiff's motion or agree to venue in Baltimore City. The undersigned attorney expects to confer again later this week on this issue and expects to reach agreement on the venue question.
  7. Even if Ms. Lasanta does not stipulate to jurisdiction in Baltimore City, this case should be consolidated in Baltimore City. GEICO does business substantial business in Baltimore City. The attorneys for both GEICO and Ms. Lasanta are located in Baltimore City. Plaintiff also received substantial medical care for his injuries in Baltimore City. Ms. Lasanta is an Anne Arundel County resident with no substantial contacts with Baltimore County. Defendants cannot meet their burden of showing that the balance weighs so strongly for Baltimore County that the Plaintiff’s proper choice of forum should be overthrown.

Accordingly, Plaintiff respectfully requests that his case against Margaria Lasanta in Baltimore County be consolidated with Plaintiff's case against GEICO in Baltimore City.

Respectfully submitted,

MILLER & ZOIS, LLC
Ronald V. Miller, Jr.
1 South St, #2450
Baltimore, MD 21202
(410)779-4600
(410)760-8922 (Fax)
Attorney for the Plaintiff

Notes on Consolidation Motions
  • Consolidating actions is proper when two or more cases involve common questions of law and fac if the judge finds that consolidation would avoid unnecessary costs or delay.
  • Consolidation serves multiple beneficial purposes. It greatly reduces the time and resources that the court will spend. It also greatly reduces the time and resources of the parties, counsel, expert witnesses, lay witnesses, and jurors. Common sense tells us that two cases as identically related as these two should be consolidated.
  • The Maryland Rules Commentary tells us that, Rule 2-503(a) was derived from former Rules 503, 561 and 606, and similar language is found in Fed. R. Civ. P. 42(a). There is not a ton of Maryland law discussing when consolidation is appropriate. So it is wise to use federal cases under Rule 42 to make your argument.
  • One big argument against consolidation is that the cases are at different stages of preparedness for trial.
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