Chorak v. Hartford Casualty Insurance Company
Trial Court Opinion
UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON 7 AT SEATTLE 8 ) CHORAK, et al ) 9 ) CASE NO. 2:20-cv-00627-BJR Plaintiffs, ) 10 ) ORDER ON CONSOLIDATION v. ) 11 ) HARTFORD CASUALTY INSURANCE ) COMPANY, et al, ) ) Defendants. ) 15 On November 11, 2020, the Court conducted a case management conference to discuss possible consolidation of this and other like matters involving claims for business insurance coverage resulting from the COVID 19 pandemic. Federal Rule of Civil Procedure 42(a) permits courts to consolidate “[i]f actions before the court involve a common question of law or fact.”
FED. R. CIV. P. 42(a). This rule affords “broad discretion” to consolidate cases pending in the same district, either upon motion by a party or sua sponte. In re Adams Apple, Inc., 829 F.2d 1484, 1487 (9th Cir. 1987). Courts consider a number of factors in analyzing the appropriateness of consolidation, including judicial economy, whether consolidation would expedite resolution of the case, whether separate cases may yield inconsistent results, and the potential prejudice to a party opposing consolidation. See 8 Moore’s Federal Practice—Civil § 42.10[4-5] (2020).
Based on the case management conference and the agreement of the parties, the Court concludes that consolidation according to insurance group will best serve judicial economy in || resolving the common issues presented by these cases. As such, the Court hereby ORDERS that || the cases involving the insurance groups under the Hartford family of insurers be consolidated.
5 || These cases include Chorak v. Hartford Casualty Insurance Company (20-cv-627); Kim v. Sentinel Insurance Company Limited (20-cv-657); Glow Medispa LLC vy. Sentinel Insurance Company Limited (20-cv-712); Strelow v. Hartford Casualty Insurance Company (20-cv-797); KCJ Studios LLC et al v. Sentinel Insurance Company Limited (20-cv-1207); Seattle Symphony Orchestra v. Hartford Fire Insurance Company (20-cv-1252); SCRBKR2017 LLC vy. Sentinel Insurance || Company Ltd (20-cv-1537); Seattle Bakery LLC et al v. Sentinel Insurance Company Ltd (20-cv- || 1540); Piroshky Piroshky Bakery LLC et al y. Sentinel Insurance Company Ltd (20-cv-1541); || Prato v. Sentinel Insurance Company Limited (20-cv-5402); Lee v. Sentinel Insurance Company Limited (20-cv-5422); and J Bells LLC v. Sentinel Insurance Company Limited (20-cv-5820), which shall be consolidated under case number 20-cv-627 as the first filed case. The Clerk of the Court is hereby notified of this consolidation.
19 DATED this 10th day of November, 2020.
71 BARBARA J. ROTHSTEIN 22 UNITED STATES DISTRICT JUDGE
Case-law data current through December 31, 2025. Source: CourtListener bulk data.