__[Attorney name]__ __[Address]__ __[Telephone number]__ Attorney for __[e.g., Plaintiff]__, _[name]__ _ _ _ _ _ _ Court, County of _ _ _ _ _ _ __[_ _ _ _ _ _ District]__ _ _ _ _ _ _ _ _ _ _ _ _ _ ) No. _ _ _ _ _ _ Plaintiff(s)) vs. )NOTICE OF MOTION TO CONSOLIDATE )__[ACTIONS/ISSUES]__; _ _ _ _ _ _ _ _ _ _ _ _ _ ) __[POINTS AND AUTHORITIES;]__ Defendant(s))__[DECLARATION(S);]__ _________________________ ) __[PROPOSED ORDER]__ Hearing: __[date; time]__ Department: _ _ _ _ _ _ __[Estimated length:_ _]__ Trial Date: __[if set]__ PLEASE TAKE NOTICE that __[e.g., plaintiff]__, __[name]__, moves the Court under Code of Civil Procedure section 1048 for an order consolidating these actions for __[all purposes/trial of the following issues: __[List issues]__]__. The grounds for issuance of this order are: 1. __[Both/All]__ these actions are pending before this Court; 2. __[Both/All]__ involve common issues of law and fact in that __[briefly specify]__; and 3. Consolidation will avoid unnecessary cost and delay. The Court is located at __[address]__. This motion is based on the attached documents and exhibits including __[specify by title (or nature) and date, e.g., the declaration of __[name]__, dated _ _ _ _]__, __[and]__ on all papers filed and records in this action __[, and on any evidence received at the hearing]__. Date: _ _ _ _ _ _ [Signature] _________________________ __[Typed name]__ Attorney for _ _ _ _ _ _ _ _ _ _
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Legal Forms : Set Two