This sample motion for consolidation of multiple cases in California is filed pursuant to Code of Civil Procedure section 1048(a) to request consolidation of two or more cases. The motion is used by a party who is requesting that a Court consolidate two or more cases on the grounds that consolidation of the cases is warranted in that all of the cases arise out of the same set of operative facts and contain common issues and further that consolidation of all of the cases will avoid unnecessary duplication of evidence and procedures in all of the actions; avoid the risk of inconsistent adjudications and avoid many of the same witnesses testifying on common issues in all actions as well as promote judicial economy and convenience. The sample on which this preview is based 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 including brief instructions, a 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 freelance paralegal who has worked in California and Federal litigation since 1995 and has created over 250 sample legal documents for sale.

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Any Attorney or Party
Any Street
Any Town, CA 99999
555-555-5555
Any Attorney or Party
Superior Court of the State of California
For the County of _____________
Any Plaintiff,
Plaintiff,
vs.
Any Defendant,
Defendant.
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Case No. LOWEST CASE NUMBER HERE
NOTICE OF MOTION AND MOTION FOR
CONSOLIDATION OF CASES; MEMORANDUM
OF POINTS AND AUTHORITIES;
DECLARATION(S) OF _______________,
EXHIBITS
DATE:
TIME:
DEPT:
Any Plaintiff,
Plaintiff,
vs.
Any Defendant,
Defendant.
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Case No.
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Any Plaintiff,
Plaintiff,
vs.
Any Defendant,
Defendant.
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Case No.
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Be sure to remove all notices before using this document.
1TO ALL INTERESTED PARTIES IN EACH CASE CAPTIONED ABOVE AND THEIR
ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE that on ________________________ at _________.M., or as soon
after that as the matter can be heard, in Dept. _______ of the above-entitled Court located at LIST
COMPLETE ADDRESS OF COURT, LIST NAME AND CAPACITY OF MOVING PARTY
(“_______”), will move the Court to order pursuant to Code of Civil Procedure § 1048(a) to
consolidate Case No. LIST CASE WITH LOWEST CASE NUMBER HERE captioned NAME
OF PLAINTIFF vs. NAME OF FIRST DEFENDANT (“________Action); Case No. LIST
CASE NUMBER OF SECOND CASE HERE captioned NAME OF PLAINTIFF vs. NAME OF
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FIRST DEFENDANT, (“________Action) and Case No. LIST CASE NUMBER OF SECOND
CASE HERE captioned NAME OF PLAINTIFF vs. NAME OF FIRST DEFENDANT,
(“______Action). The motion should be granted on the grounds that all of the Actions arise out of the
same set of operative facts namely LIST HERE THE SAME SET OF OPERATIVE FACTS and
contain common issues in that LIST HERE THE ISSUES THAT ARE COMMON TO ALL OF
THE ACTIONS. Consolidation of all of the Actions will avoid unnecessary duplication of evidence
and procedures in all of the actions; avoid the risk of inconsistent adjudications and avoid many of
the same witnesses testifying on common issues in all actions as well as promote judicial economy
and convenience.
The Motion will be based on this notice, the attached memorandum of points and authorities,
the attached Declaration of _____________________ and Exhibits attached thereto, the records and
files of this action, and the oral and documentary evidence which may be introduced at the hearing.
Dated________________ _______________________________________________
ANY ATTORNEY OR PARTY
Be sure to modify these paragraphs to suit your individual
situation. Do NOT just use the wording here unless it definitely applies
to your particular situation. Be sure to add or subtract case captions as
necessary and list the case with the lowest case number first.
Note that this motion should only be used when all cases are pending in
the same Court.
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You must serve all parties in every case who have made an
appearance with this entire motion including all supporting documents.
You only have to file the entire motion in the case with the lowest case
number which is known as the lead case. You only need to file the
notice of motion and proof of service in all of the other cases. See
California Rule of Court. 3.350 for more details.
You should file this motion within a reasonable period of time
after you discover the need for consolidation of the cases and you must
give at least sixteen (16) Court days notice, plus an additional five (5)
calendar days if the motion is served by mail. Note that Court days
includes Monday through Friday except for Court holidays.
Check your local Court rules as they may have additional
requirements for filing a motion to consolidate.
To view the sample document on which this preview is based visit:
https://www.scribd.com/doc/252125223/Sample-Motion-for-
Consolidation-of-Cases-in-California
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