[COURT NAME]
[DIVISION] DIVISION

[PLAINTIFF NAME(S)], §
§
Plaintiff[s], §
§ CIVIL ACTION NO. [CASE NO.]
v. §
§
[DEFENDANT NAME(S)], §
§
Defendant[s]. §
________________________________________________§______________________________________________

[MOVING PARTY] MOTION TO CONSOLIDATE CASES
________________________________________________________________________________________________

[// GUIDANCE: Insert any required local-rule header language here.]

NOTICE OF MOTION AND MOTION

PLEASE TAKE NOTICE that on [HEARING DATE] at [TIME], or as soon thereafter as counsel may be heard, [MOVING PARTY] will and hereby does move the Court to consolidate this action with the following related case(s) pursuant to Fed. R. Civ. P. 42(a):
- [CASE NAME], Case No. [NUMBER], Judge [NAME]
- [CASE NAME], Case No. [NUMBER], Judge [NAME]

This Motion is based on the accompanying memorandum, declarations, the pleadings on file, and such other argument or evidence as may be presented.

MEMORANDUM OF POINTS AND AUTHORITIES

I. Introduction

Consolidation is appropriate because the cases involve common questions of law and fact, and consolidation will promote efficiency and avoid inconsistent rulings.

II. Background

• Case 1: [SUMMARY OF CLAIMS, PARTIES, PROCEDURAL POSTURE].
• Case 2: [SUMMARY OF CLAIMS, PARTIES, PROCEDURAL POSTURE].
• Overlapping issues: [LIST COMMON FACTS/LEGAL ISSUES].

III. Legal Standard

Under Rule 42(a), the Court may consolidate actions that involve common questions of law or fact, considering efficiency, potential prejudice, and the risk of confusion.

IV. Argument

A. The cases share common questions of law and fact.
[Explain the overlap.]

B. Consolidation will promote efficiency and reduce costs.
[Explain duplication of discovery, motions, or witnesses.]

C. Consolidation will not prejudice any party.
[Explain why consolidation will not cause unfair delay or confusion.]

V. Requested Relief

[MOVING PARTY] respectfully requests that the Court:
1. Consolidate the cases listed above under Case No. [LEAD CASE].
2. Set a consolidated schedule and designate a lead case caption.
3. Grant any other relief the Court deems just.

CONCLUSION

For the foregoing reasons, the Court should grant the Motion to Consolidate.

Respectfully submitted,

text
Dated: [DATE]

______________________________
[ATTORNEY NAME]
[LAW FIRM]
[ADDRESS]
[PHONE]
[EMAIL]
Attorney for [MOVING PARTY]

CERTIFICATE OF SERVICE

I certify that on [DATE], I served the foregoing Motion to Consolidate on all counsel of record via [METHOD OF SERVICE] in compliance with Fed. R. Civ. P. 5.

text
______________________________
[ATTORNEY NAME]

[PROPOSED] ORDER

The Court, having considered [MOVING PARTY]'s Motion to Consolidate, ORDERS as follows:
1. The Motion is GRANTED.
2. The following cases are consolidated under lead Case No. [LEAD CASE].
3. The consolidated case shall proceed under a unified schedule to be set by the Court.

IT IS SO ORDERED.

Dated: [DATE]

______________________________________
[JUDGE NAME]
United States District Judge