concurring.
I concur in the result for the reasons set forth in the final few paragraphs of the majority opinion — Appellant provides no support for her assertion that, upon consolidation of actions, claims asserted on behalf of one party automatically and retroactively become claims asserted on another party’s behalf. To the contrary, I believe that, even in the very strongest form of consolidation, distinct counts set forth in the individual complaints should remain as such in the consolidated action, with any additional claims to be asserted via appropriate cross-, counter-, or third-party pleadings. A looser approach permitting automatic, retroactive consolidation of counts to encompass unstated cross-claims is untenable, since *538the potential for disorder, confusion, and surprise simply is too great.
Regarding the balance of the majority opinion, I have a number of differences. Principally, I do not see what is left of full substantive consolidation as contemplated by Azinger v. Pennsylvania Railroad Company, 262 Pa. 242, 105 A. 87 (1918), in the aftermath of Rule of Civil Procedure 1020(d), embodying the compulsory joinder rule. To the degree anything is left, I do not understand why such consolidation is outside the scope of Rule 213(a), which indicates that a trial judge “may order ... actions consolidated.” Pa.R.Civ.P. No. 213(a).
Concerning the majority’s discussions of the case law, I am unable to recognize the litmus by which the majority is determining same-party status. For example, in discussing Mosside Associates, Ltd. v. ZHB of Monroeville, 70 Pa. Cmwlth. 555, 454 A.2d 199 (Pa.Cmwlth.1982), and Keefer v. Keefer, 741 A.2d 808 (Pa.Super.1999), the majority indicates that both decisions involved the same parties. See Majority Opinion, at 533, 999 A.2d at 496, 497. Nevertheless, Mosside involved appeals by legally distinct entities (a planning commission and its individual members). See Mosside, 70 Pa. Cmwlth. at 557-58, 454 A.2d at 201. As to Keefer, although there is substantial overlap among the parties to the multiple consolidated actions in that case, some of the underlying complaints appear to have involved distinct individuals. See Brief for Appellant, Keefer v. Keefer, 741 A.2d 808 (Pa.Super.1999), 1999 WL 33888882, at 4-8 (Jan. 1, 1999). Therefore, it is not clear whether the majority approach to same-party status contemplates overlap or complete identity.1
Finally, in light of the flexibility integrated into Rule 213, I would reiterate Keefer’s admonition that it would greatly facilitate appellate review if the trial courts would employ a degree of precision in orders under that rule. See Keefer, 741 *539A.2d at 811 n. 3. Parties seeking extraordinary approaches to consolidation (as, for example, Appellant has pursued on appeal here in the form of retroactive consolidation with reconstituted counts), should obviously put the court and other parties on notice of what is being pursued. This will allow for fair and informed responses by the litigants and decision-making by the court.
Justice EAKIN joins this concurring opinion.. Neither Mosside nor Keefer was framed to consider the same-party issue. In the absence of a sharper focus in the written decisions, I question the helpfulness of judgments on the same-party question relative to those opinions at this juncture.