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Chapter 8

Form 8-32

Include the following notice if a minor is named in the caption or if the motion contains other unredacted sensitive data. See § 6 of the Introduction in volume 1 of this manual concerning protection of sensitive data in filed documents.

NOTICE: THIS DOCUMENT
CONTAINS SENSITIVE DATA

[Caption. See § 3 of the Introduction in volume 1 of this manual.]

Provide captions for both cases.

Motion to Consolidate

This Motion to Consolidate the above lawsuits is brought by [name of movant], who shows in support:

1.These lawsuits involve [a] common question[s] of law or of fact.

2.It would serve the convenience of the Court, litigants, and counsel and would avoid multiplicity of suits, duplication of testimony, and unnecessary expense and delay to have these lawsuits consolidated for trial.

[Name of movant] prays that the Court grant the Motion to Consolidate and consolidate these lawsuits under the older and lower cause number.

   
[Name]
Attorney for [name of movant]
State Bar No.:
[E-mail address]
[Address]
[Telephone]
[Fax]

Notice of Hearing

The above motion is set for hearing on __________________ at ____________ __.m. in [designation and location of court].

SIGNED on ________________________________.

   
Judge or Clerk

Certificate of Service

I certify that a true copy of this [document/[title of document]] was served in accor­dance with rule 21a of the Texas Rules of Civil Procedure on the following on [date]:

[Name of attorney of record or party to be served] by [electronic filing manager/e-mail at [e-mail address]/fax at [fax number]/personal delivery at [address]/commercial delivery service at [address]/certified mail at [address]/first-class mail at [address]]. [Repeat for each attorney of record or party to be served.]

   
[Name]
Attorney for [name of movant]