Klein v. Jafri
- Tarnofsky
- 1:24-cv-01649
- U.S. District Court · Southern District of New York
- 2
In Klein v. Jafri, Judge Tarnofsky consolidated two identical federal lawsuits for all purposes because they shared defendants, claims, and requested relief.
David Klein and the defendants in the two related actions. The cases will proceed as one consolidated action under the New York docket.
What happened
In Klein v. Jafri, David Klein filed identical lawsuits in federal courts in New York and California. The California case was later transferred to New York, and both cases were still at an early stage with no discovery completed or scheduled.
The court considered whether the cases should be combined under Rule 42(a) of the Federal Rules of Civil Procedure. That rule allows courts to combine cases involving common legal or factual questions. The court found consolidation appropriate because the complaints asserted the same causes of action against nearly identical defendants and sought the same relief.
Judge Robyn F. Tarnofsky ordered the two cases consolidated for all purposes. The Clerk was requested to combine them under the New York case's docket, 24-CV-01649.
The detailed version
- Klein v. Jafri · No. 1:24-cv-01649
- Tarnofsky
- May 8, 2025
Background
David Klein filed identical lawsuits on March 4, 2024, one in the Southern District of New York and one in a federal court in California. The New York case was referred to Magistrate Judge Robyn F. Tarnofsky for general pretrial supervision. The California case was later transferred to the Southern District of New York and accepted as related to the New York case.
Both actions were at an early stage. The opinion states that discovery had not been completed or scheduled. After a May 1, 2025 status conference, the court addressed whether to consolidate the cases for all purposes.
Rule and Analysis
Federal Rule of Civil Procedure 42(a) permits a court to consolidate cases that involve common questions of law or fact. The court explained that consolidation was especially appropriate because both complaints alleged the same causes of action, named virtually identical defendants, and sought the same relief.
Ruling
The court ordered the New York Action and the California Action consolidated for all purposes. It requested that the Clerk consolidate the actions under the New York case, 24-CV-01649 (AT) (RFT).
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.