Notice of Motion and Motion for Leave to Deposit Interpleader, RMJ Small Biz LLC v. Occams Advisory Inc.
Summary
In this motion filed December 12, 2025, in RMJ Small Biz LLC v. Occams Advisory Inc., Occams Advisory Inc. asks the Central District of California for an order directing the Clerk to accept for deposit into the Court Registry the amount of $1,315,589.08, under Rule 67 of the Federal Rules of Civil Procedure. The motion states that Occams possesses the Disputed Funds, which it contractually owes to RMJ Small Biz LLC and/or ConnectMyBiz, LLC, but cannot determine the proper recipient because the two have asserted competing claims. It says CMB has threatened legal action and RMJ has already filed suit, and that Occams makes no claim to the funds. The hearing was noticed for February 4, 2026, at 1:30 p.m. before Judge Serena R. Murillo; the signature block names David E. Fink and Witt W. Chang of Venable LLP.
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“Notice of Motion and Motion for Leave to Deposit Interpleader, RMJ Small Biz LLC v. Occams Advisory Inc.”
Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/25-interpleader-deposit-motion-b7ed6dff39/
, SHA-256 315d649c139b724c95bf235939d702eedce7792d6efd0cdb1b400acf67cd7fdf.Full text
Case 2:25-cv-07956-SRM-MAR Document 25 Filed 12/12/25 Page 1 of 6 Page ID
#:278
1 VENABLE LLP
David E. Fink (SBN 169212)
2 DEFink@Venable.com
Witt W. Chang (SBN 281721)
3 WWChang@Venable.com
2049 Century Park East, Suite 2300
4 Los Angeles, CA 90067
Telephone: 310.229.9900
5 Facsimile: 310.229.9901
6 Attorneys for Defendant and Counterclaimant
and Third-Party Plaintiff Occams Advisory Inc.
7
8
UNITED STATES DISTRICT COURT
9
CENTRAL DISTRICT OF CALIFORNIA
10
LOS ANGELES DIVISION
11
12 RMJ Small Biz LLC, a
2049 CENTURY PARK EAST, SUITE 2 300
Tennessee limited liability Case No. 2:25-CV-7956
13 company,
VENABLE LLP
14 Plaintiff, OCCAMS ADVISORY INC.’S NOTICE
LOS ANGELES, CA 90067
310.229.9900
OF MOTION AND MOTION FOR
15 v. LEAVE TO DEPOSIT INTERPLEADER
FUNDS WITH THE COURT
16 PURSUANT TO FED. R. CIV. P. 67
Occams Advisory Inc., a
17 Delaware Corporation, and
Anupam Satyasheel, an
18 individual, Date: February 4, 2026
Time: 1:30 p.m.
19 Defendants. Judge: Hon. Serena R. Murillo
Courtroom: 5D
20
21 Complaint Filed: Nov. 7, 2025
Interpleader Counterclaim Filed: Dec. 12, 2025
22 Occams Advisory Inc., a
Delaware Corporation,
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Counterclaimant,
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v.
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RMJ Small Biz LLC, a
26 Tennessee limited liability
company,
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Counterdefendant.
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MOTION FOR LEAVE TO DEPOSIT INTERPLEADER FUNDS WITH THE COURT
Case 2:25-cv-07956-SRM-MAR Document 25 Filed 12/12/25 Page 2 of 6 Page ID
#:279
1
Occams Advisory Inc., a
2 Delaware Corporation,
3 Third-Party Plaintiff,
4 v.
5 ConnectMyBiz, LLC, a North
Carolina limited liability
6 company,
7 Third-Party Defendant
in Interpleader.
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9 Occams Advisory Inc., a
Delaware Corporation,
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Third-Party Plaintiff,
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v.
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DOES 1 through 20, inclusive,
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Third-Party
14 Defendants Unrelated to
Interpleader.
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MOTION FOR LEAVE TO DEPOSIT INTERPLEADER FUNDS WITH THE COURT
Case 2:25-cv-07956-SRM-MAR Document 25 Filed 12/12/25 Page 3 of 6 Page ID
#:280
1 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
2 PLEASE TAKE NOTICE that on February 4, 2026, at 1:30 p.m., or as soon
3 thereafter as the parties may be heard, in the courtroom of the Honorable Serena R.
4 Murillo at 350 W 1st Street, Suite 4311 Los Angeles, CA 90012-4565, Courtroom
5 5D, 5th Floor, Defendant, Counterclaimant, and Third-Party Plaintiff Occams
6 Advisory Inc. (“Occams”), by and through undersigned counsel, will and hereby
7 moves the Court for an order to deposit interpleader funds with the Court pursuant
8 to Rule 67 of the Federal Rules of Civil Procedure.
9 This Motion is based on the Notice of Motion and Motion for Leave to
10 Deposit Interpleader Funds, the Memorandum of Points and Authorities in Support
11 thereof, the Declaration of David E. Fink, Occams’ concurrently filed Counterclaim
12 and Third-Party Complaint in Interpleader, and upon such other oral and written
13 materials as may be presented at or before the hearing on this matter.
14
15 Dated: December 12, 2025 VENABLE LLP
16
17 By: David E. Fink
Witt W. Chang
18
Attorneys for
19 Defendant/Counterclaimant/Third-
Party Plaintiff Occams Advisory
20 Inc.
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MOTION FOR LEAVE TO DEPOSIT INTERPLEADER FUNDS WITH THE COURT
Case 2:25-cv-07956-SRM-MAR Document 25 Filed 12/12/25 Page 4 of 6 Page ID
#:281
1 MEMORANDUM OF POINTS AND AUTHORITIES
2 Pursuant to Rule 67 of the Federal Rules of Civil Procedure, Local Rule 67,
3 and General Order 16-04, Defendant, Counterclaimant, and Third-Party Plaintiff
4 Occams Advisory Inc. (“Occams”), by and through undersigned counsel,
5 respectfully requests that the Court enter an order directing the Clerk of Court to
6 accept for deposit into the Court Registry the amount of $1,315,589.08.
7 As set forth in the attached Declaration of David E. Fink, Occams is in
8 possession of $1,315,589.08 (the “Disputed Funds”) it contractually owes to either
9 Plaintiff and Counterdefendant RMJ Small Biz LLC (“RMJ”) and/or Third-Party
10 Defendant ConnectMyBiz, LLC (“CMB”), but it cannot reasonably determine the
11 proper recipient of the Disputed Funds because RMJ and CMB have asserted
12 competing claims to said funds.
13 “Interpleader is a procedure authorized by 28 U.S.C. § 1335 and Federal Rule
14 of Civil Procedure 22.” Reliastar Life Ins. Co. v. Northam, No. 2:13-cv-00063-
15 TLN-JFM, 2013 U.S. Dist. LEXIS 149072, at *4 (E.D. Cal. Oct. 10, 2013). “When
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a person holding funds or property (the stakeholder) encounters other parties who
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are making conflicting possessory claims for those funds or property, he may join
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the parties as defendants and require them to litigate who is entitled to the funds or
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property.” Id. at *4-5 (citing Michelman v. Lincoln Nat. Life. Ins., Co., 685 F.3d
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887, 893 (9th Cir. 2012)). “The main purpose of interpleader actions is to protect
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the stakeholder from the expenses of multiple lawsuits and from having to contend
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with inconsistent or multiple determinations of liability.” Id. at *5 (citing Texas v.
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Florida, 306 U.S. 398, 406-07 (1939)).
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To bring an interpleader action, the interpleading party must “have control
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over a particular fund or property.” Id. (citing Mock v. Collins, No. EDCV 04-395-
26
VAP SGLX, 2004 WL 3619122, at *2 (C.D. Cal. Sept. 1, 2004)). “Further, there
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must be multiple, adverse claims made to that same property or fund.” Id. (citing
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MOTION FOR LEAVE TO DEPOSIT INTERPLEADER FUNDS WITH THE COURT
Case 2:25-cv-07956-SRM-MAR Document 25 Filed 12/12/25 Page 5 of 6 Page ID
#:282
1 Libby, Mcneill & Libby v. City Nat’l Bank, 592 F.2d 504, 507 (9th Cir. 1978)).
2 Finally, the stakeholder “must have a reasonable fear of multiple liability.” Id.
3 Occams is ready, willing, and able to pay the Disputed Funds. Indeed, were
4 it not for CMB and RMJ’s ongoing and competing claims to the same funds,
5 Occams would already have paid the Disputed Funds to the proper recipient.
6 However, Occams has a reasonable fear of multiple liability given that CMB has
7 threatened legal action against Occams to recover the Disputed Funds, and RMJ has
8 already filed suit against Occams relating to same.
9 Occams has and makes no claim to, and is a disinterested stakeholder in, the
10 Disputed Funds, and therefore moves to deposit the Disputed Funds into the Court
11 Registry Investment System Disputed Ownership Fund (“CRIS DOF”) pursuant to
12 federal and local rules. The amount of Disputed Funds to be deposited,
13 $1,315,589.08, reflects the maximum amount of money owed to RMJ and/or CMB.
14 This Motion is accompanied by a Proposed Order Directing the Clerk of
15 Court to Deposit Funds into an interest-bearing account with the Court Registry
16
pursuant to Rule 67 of the Federal Rules of Civil Procedure, Local Rule 67-1, and
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Central District of California General Order 16-04.
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WHEREFORE, Occams respectfully requests that the Court enter an Order
19
directing the Clerk of Court to accept deposit in the amount of $1,315,589.08 into
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an interest-bearing CRIS DOF account.
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22 Dated: December 12, 2025 VENABLE LLP
23
24 By: David E. Fink
Witt W. Chang
25
Attorneys for
26 Defendant/Counterclaimant/Third-
Party Plaintiff Occams Advisory
27 Inc.
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MOTION FOR LEAVE TO DEPOSIT INTERPLEADER FUNDS WITH THE COURT
Case 2:25-cv-07956-SRM-MAR Document 25 Filed 12/12/25 Page 6 of 6 Page ID
#:283
1 CERTIFICATE OF COMPLIANCE
2 The undersigned, counsel of record for Defendant, Counterclaimant, and
3 Third-Party Plaintiff Occams Advisory Inc. (“Occams”), certifies that this brief
4 contains 546 words, which complies with the word limit of L.R. 11-6.1.
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6 Dated: December 12, 2025 VENABLE LLP
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8 By: David E. Fink
Witt W. Chang
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Attorneys for
10 Defendant/Counterclaimant/Third-
Party Plaintiff Occams Advisory
11 Inc.
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CERTIFICATE OF COMPLIANCE
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