__[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