context: Nonetheless, if the complaint alleges essentially one cause of action, pendent venue may extend to Counts III and IV. In determining whether a case can be described as a single cause of action, courts examine whether the plaintiff has asserted essentially one wrong, whether the grounds for relief are the same as to the parties and proof, and whether there will be "great commonality as to witnesses and evidence."
citation_a.signal: see
citation_a.identifier: 321 F.Supp. 1041, 1042
citation_a.parenthetical: extending pendent venue to the plaintiffs Civil Rights Act claim because venue was proper under the Equal Pay Act claim and the two separate causes of action arose out of common allegations of employment discrimination against female flight attendants
citation_a.sentence: Beattie, 756 F.2d at 101 (describing the litigation “as a single cause of action with separate grounds for relief’ because the plaintiffs seek damages for “ ‘an essentially single wrong,’ i.e., wrongful death” (footnote omitted)); see, e.g., Zenith Radio Corp. v. Matsushita Elec. Indus. Co., 402 F.Supp. 262, 328 n. 38 (E.D.Pa.1975) (applying pendent venue in a ease involving both the Anti-Dumping Act of 1916 and federal antitrust law because it would be “senseless ... to bifurcate these two exceedingly complex antitrust cases by dismissing or transferring the antidumping counts while retaining the antitrust counts since the facts underlying both sets of issues are essentially the same”); Laffey v. Northwest Airlines, 321 F.Supp. 1041, 1042 (D.D.C.1971) (extending pendent venue to the plaintiffs Civil Rights Act claim because venue was proper under the Equal Pay Act claim and the two separate causes of action arose out of common allegations of employment discrimination against female flight attendants).
citation_b.signal: cf.
citation_b.identifier: 725 F.Supp. 606, 606
citation_b.parenthetical: refusing to extend pendent venue because, although plaintiffs discrimination claims were based on the conduct of a single supervisor, each claim alleged discriminatory conduct against a different protected class, the evidence to support each discrimination claim would of necessity be different, and the suit included nondiscrimination claims based on administrative law issues
citation_b.sentence: Cf. Archuleta, 725 F.Supp. at 606 (refusing to extend pendent venue because, although plaintiffs discrimination claims were based on the conduct of a single supervisor, each claim alleged discriminatory conduct against a different protected class, the evidence to support each discrimination claim would of necessity be different, and the suit included nondiscrimination claims based on administrative law issues).