Crist v. EisnerAmper LLP

CourtDistrict Court, D. Minnesota
DecidedMay 27, 2025
Docket0:25-cv-01573
StatusUnknown

This text of Crist v. EisnerAmper LLP (Crist v. EisnerAmper LLP) is published on Counsel Stack Legal Research, covering District Court, D. Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Crist v. EisnerAmper LLP, (mnd 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA

CHRISTOPHER NIOSI, individually, Case No. 25-cv-1409 (LMP/DTS) and on behalf of all others similarly situated,

Plaintiff, ORDER

v.

EISNER ADVISORY GROUP LLC,

Defendant.

ANDREW MARSTON, individually, and Case No. 25-cv-1568 (LMP/DTS) on behalf of all others similarly situated,

Plaintiff,

ROBERT CRIST and REBECCA L. Case No. 25-cv-1573 (LMP/DTS) LEMMONS, individually and on behalf of all others similarly situated,

Plaintiffs,

EISNERAMPER LLP and EISNER ADVISORY GROUP LLC,

Defendants. On April 8, 2025, Defendant Eisner Advisory Group LLC (“Eisner”)—an accounting and auditing firm—gave public notice that it suffered a data breach in September 2023 that affected more than 85,000 individuals. See ECF No. 1 ¶¶ 1–2.1 Shortly thereafter, Christopher Niosi and Andrew Marston (individually) and Robert Crist

and Rebecca L. Lemmons (jointly) (collectively, “Plaintiffs”) filed separate class action complaints against Eisner, asserting claims arising out of that data breach. See generally id.; Marston v. Eisner Advisory Grp. LLC, No. 25-cv-1568 (LMP/DTS) (D. Minn. Apr. 17, 2025), ECF No. 1; Crist v. EisnerAmper LLP, No. 25-cv-1573 (LMP/DTS) (D. Minn. Apr. 17, 2025), ECF No. 1. Presently before the Court is Plaintiffs’ joint motion to consolidate the three cases

and to appoint interim co-lead counsel pending class certification. ECF No. 6. Eisner does not oppose the motion. ECF No. 7 at 2. For the following reasons, the Court grants the joint motion and consolidates the three cases into case number 25-cv-1409 under the caption In re Eisner Advisory Group Data Breach Litigation. I. Consolidation

A court may consolidate cases in which the claims and issues share common questions of law or fact. E.E.O.C. v. HBE Corp., 135 F.3d 543, 550 (8th Cir. 1998) (citing Fed. R. Civ. P. 42(a)). Consolidation is appropriate if it helps avoid “unnecessary cost or delay” and furthers judicial economy. See HBE Corp., 135 F.3d at 550. “Consolidation is

1 Unless otherwise noted, citation to docket entries is to Niosi v. Eisner Advisory Group LLC, 25-cv-1409 (LMP/DTS) (D. Minn.). inappropriate, however, if it leads to inefficiency, inconvenience, or unfair prejudice to a party.” Id.

The three complaints here undoubtedly involve common questions of law and fact. Each relates to Eisner’s September 2023 data breach, and each asserts similar, if not identical, legal claims. Compare ECF No. 1 ¶¶ 74–115 (alleging negligence, breach of third-party beneficiary contract, and unjust enrichment), with Marston, No. 25-cv-1568, ECF No. 1 ¶¶ 89–139 (alleging negligence, breach of contract, unjust enrichment, and invasion of privacy), and Crist, No. 25-cv-1573, ECF No. 1 ¶¶ 109–185 (alleging

negligence, breach of third-party contract, breach of fiduciary duty, breach of confidence, unjust enrichment, and violations of California statutes). And each Plaintiff seeks to represent all similarly-situated individuals nationwide. “Because the plaintiffs’ claims each arise out of the same data breach, contain overlapping causes of action, and seek to represent the same class of individuals, all of the above-captioned actions will involve

common questions of law and fact.” Schultz v. TD Ameritrade, Inc., No. 8:23-cv-375, 2023 WL 6621073, at *1 (D. Neb. Oct. 11, 2023). Consolidating the cases will also promote judicial efficiency and avoid unnecessary costs and delays. Indeed, the parties propose consolidating into the first-filed case, No. 25- cv-1409, filing a joint consolidated complaint in that case, and administratively closing the

other two cases. ECF No. 9 at 2. Such action would benefit all parties and the Court by limiting duplicative filings. Accordingly, the Court grants Plaintiffs’ unopposed request to consolidate. II. Interim Co-Lead Counsel and Liaison Counsel Plaintiffs further ask the Court to approve an interim co-lead class counsel structure

in which Carl V. Malmstrom (counsel for Niosi), Philip J. Krzeski (counsel for Marston), and Marc H. Edelson (counsel for Crist and Lemmons) are appointed as co-lead counsel, and David A. Goodwin (counsel for Crist and Lemmons) is appointed as liaison counsel. See id. at 4. Under Federal Rule of Civil Procedure 23(g)(3), the Court may designate interim class counsel before determining whether to certify a class. “Instances in which interim

class counsel is appointed are those in which overlapping, duplicative, or competing class suits are pending before a court, so that appointment of interim counsel is necessary to protect the interests of class members.” Bartling v. Apple Inc., No. 5:18-cv-00147-EJD, 2018 WL 4804735, at *1 (N.D. Cal. Apr. 27, 2018) (citation omitted). When considering the appointment of interim class counsel, courts consider counsel’s: (1) work in identifying

or investigating potential claims; (2) experience in handling class action and complex litigation and the types of claims asserted in the action; (3) knowledge of the applicable law; and (4) available resources. Adedipe v. U.S. Bank, Nat’l Ass’n, No. 13-cv-2687 (JNE/JJK), 2014 WL 835174, at *2 (D. Minn. Mar. 4, 2014) (citing Fed. R. Civ. P. 23(g)(1)(A)).

Considering the four factors, the Court is assured that each of the proposed lead counsel, together with their respective firms, could be appointed as interim lead counsel. Malmstrom, Krzeski, and Edelson, and the firms at which they work, have extensive experience as lead counsel in other nationwide class actions, experience dealing with classes alleging claims like those here, and ample resources to effectively litigate the case moving forward. See generally ECF No. 8 at 10–18.

The question is whether to appoint them as co-lead counsel. Though Rule 23(g) does not specifically contemplate co-lead counsel structures, “it is not unusual for multiple firms to serve as interim co-lead counsel.” Moehrl v. Nat’l Ass’n of Realtors, No. 19-cv- 1610, 2020 WL 5260511, at *2 (N.D. Ill. May 30, 2020) (collecting cases). This is particularly true where a case is complex, involves many potential class members, and the proposed co-lead counsel can work harmoniously. See id.; see also In re Int. Rate Swaps

Antitrust Litig., No. 16-md-2704 (PAE), 2016 WL 4131846, at *4 (S.D.N.Y. Aug. 3, 2016) (noting that appointing co-lead counsel “has become common practice” in complex antitrust class actions); Piercy v. AT&T Inc., 348 F.R.D. 1, 3 (D. Mass. 2024) (appointing co-lead counsel where counsel were “sufficiently experienced to allow coordination of the proceedings in a manner that will avoid unnecessary duplication”); Breakwater Trading

LLC v. JPMorgan Chase & Co., No. 20-cv-3515 (PAE), 2020 WL 5992344, at *4 (S.D.N.Y. Oct. 9, 2020) (“An ability to work with other plaintiffs’ counsel can benefit the class by permitting interim lead counsel to utilize the talent and resources of other counsel without the need for a formal executive or steering committee.”). Nevertheless, appointing multiple firms as co-lead counsel runs the risk of

“duplicative services and the concomitant increase in attorneys’ fees.” In re Milestone Sci. Sec. Litig., 183 F.R.D. 404, 418 (D.N.J. 1998). But such an arrangement still may be warranted “so long as ‘the interest of all class members will be vigorously, professionally, yet efficiently handled.’” Piercy, 348 F.R.D. at 3 (quoting McMorris v. TJX Cos., 493 F. Supp. 2d 158, 167 (D. Mass. 2007)).

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McMorris v. TJX Companies, Inc.
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