[COURT NAME]
[COUNTY], [STATE]

[PLAINTIFF NAME], )
Plaintiff, ) Case No. [CASE NUMBER]
v. )
[DEFENDANT NAME], )
Defendant. )

MOTION TO CONSOLIDATE RELATED CASES

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 for an order consolidating this action with [RELATED CASE NAME(S) AND NUMBER(S)].

MEMORANDUM OF POINTS AND AUTHORITIES

I. Introduction

Consolidation is appropriate because the actions involve common questions of law and fact, and consolidation will promote efficiency without prejudice to any party.

II. Background

• This action: [SUMMARY]
• Related action(s): [SUMMARY]
• Common issues: [LIST]

III. Legal Standard

Courts may consolidate actions that involve common questions of law or fact to avoid unnecessary cost or delay and to promote efficient case management.

IV. Argument

A. The actions share common questions of law and fact.
[Identify overlapping claims, parties, or evidence.]

B. Consolidation will promote judicial economy.
[Explain efficiencies in discovery, motion practice, and trial.]

C. Consolidation will not prejudice any party.
[Address any potential prejudice and how it can be mitigated.]

V. Requested Relief

[MOVING PARTY] respectfully requests that the Court:
1. Consolidate this action with [RELATED CASE NAME(S)].
2. Assign a single case number and coordinating judge, if required.
3. Set a consolidated case management schedule.

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].

text
______________________________
[ATTORNEY NAME]

[PROPOSED] ORDER

The Court, having considered the Motion to Consolidate, ORDERS as follows:
1. This action is consolidated with [RELATED CASE NAME(S)].
2. The consolidated cases shall proceed under Case No. [CONSOLIDATED CASE NUMBER].
3. A consolidated case management conference is set for [DATE].

IT IS SO ORDERED.

Dated: [DATE]

__________________________________
[JUDGE NAME]
[STATE] Judge