Corona Group, LLC v. Park
- Gregory Woods
- 1:21-cv-02889
- U.S. District Court · Southern District of New York
- 2
In Corona Group v. Park, Judge Woods ordered information about JPark’s legal form and citizenship before deciding whether to add it as a defendant.
Corona Group, LLC, Jeff Park, and the non-party JPark entity whose legal form and citizenship were at issue.
What happened
Corona Group, LLC asked to add non-party JPark Management Group, LLC as a defendant. Court records used different names for the JPark entity, including a corporation and an LLC.
The court said JPark’s legal form and citizenship could affect federal jurisdiction and the request to add it to the case. It did not decide the joinder request; instead, it ordered Jeff Park to file a sworn affidavit answering specific questions about JPark by November 7, 2022.
Judge Gregory H. Woods issued the order on November 3, 2022. The order required clarification of JPark’s organization, state connections, and—if it was an LLC—the citizenship of each member.
The detailed version
- Corona Group, LLC v. Park · No. 1:21-cv-02889
- Gregory Woods
- Nov. 3, 2022
Background
Corona Group, LLC moved to join “non-party JPark Management Group, LLC” as a defendant. The record used conflicting names and descriptions for the JPark entity. Some documents referred to “JPark Management, Inc.” or “JPark Management Group Inc.,” while a lease identified “JPark Management Group LLC” as the tenant.
Jurisdictional concern
The court explained that JPark’s legal form and citizenship could affect federal jurisdiction and the motion to join it. If JPark were an LLC, its citizenship would depend on the citizenship of each member, and the court also wanted to know under which state’s laws it was organized. If JPark were a corporation, the court sought confirmation of its state of incorporation and principal place of business.
Order
The court ordered Jeff Park to file a sworn affidavit by November 7, 2022, answering three questions: whether JPark was a corporation or an LLC; if it was a corporation, where it was incorporated and where it had its principal place of business; and if it was an LLC, the citizenship of each member and the state whose laws organized it. The court did not rule on Corona Group’s motion to join JPark as a defendant in this order.
Effect
This was an information-gathering order addressing issues relevant to jurisdiction and joinder. It did not decide the underlying dispute or determine whether JPark would be added as a defendant.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.