Sample Motion for Consolidation of Cases in California.

This sample motion for consolidation of cases in California is filed pursuant to Code of Civil Procedure section 1048(a) to request consolidation of two or more cases. Note that this motion should ONLY be used where all of the cases are pending in the same Court.

The motion is made on the grounds that,

• Consolidation of two or more cases is warranted in that all of the cases arise out of the same set of operative facts and contain common issues, 
• Consolidation of all of the cases will (1) avoid unnecessary duplication of evidence and procedures in all of the actions; (2) avoid the risk of inconsistent adjudications, (3) avoid many of the same witnesses testifying on common issues in all actions as well as (4) promote judicial economy and convenience. 

The sample can be easily modified for use in cases where complete consolidation is requested or where consolidation is requested only for purposes of trial and is 19 pages and includes,

• Brief instructions,
• Memorandum of points and authorities with citations to case law and statutory authority,
• Sample declaration,
• Proof of service by mail, and
• Proposed order. 

The author is an entrepreneur and retired litigation paralegal that worked in California and Federal litigation from January 1995 through September 2017 and has created over 300 sample legal documents for sale.

• Note that the author is NOT an attorney and no guarantee or warranty is provided.