Medical Malpractice Motion 13 - motion to consolidate

Download PDF Version


Plaintiff's Motion to Consolidate

NOW COMES the plaintiff, HOWARD KIRKHAM, by his attorneys, ROBERT B. PATTERSON, LTD., and moves this Court to consolidate case number 98 L 10971 into case number 97 L 5196. In support of this Motion, plaintiff states as follows:

1. Both cases are medical malpractice actions which allege that the defendants failed to diagnose a bone cyst and/or lesion on the talus of plaintiff's left foot.

2. Dr. Glen Geremia, the defendant in 98 L 10971, was originally a named defendant in 97 L 5196, but was voluntarily dismissed, without prejudice, on April 13, 1998.

3. On September 22, 1998, the claim against Dr. Geremia was refiled and given case number 98 L 10971.

4. Because the two cases involve common facts and common injuries, the plaintiff moves that the two actions be consolidated for purposes of discovery and trial.

WHEREFORE, the plaintiff, HOWARD KIRKHAM, respectfully requests that this Court consolidate case number 98 L 10971 into case number 97 L 5196.

Client Reviews
Jonathan Rosenfeld was professionally objective, timely, and knowledgeable. Also, his advice was extremely effective regarding my case. In addition, Jonathan was understanding and patient pertaining to any of my questions or concerns. I was very happy with the end result and I highly recommend Jonathan Rosenfeld.
★★★★★
Extremely impressed with this law firm. They took control of a bad motorcycle crash that left my uncle seriously injured. Without any guarantee of a financial recovery, they went out and hired accident investigators and engineers to help prove how the accident happened. I am grateful that they worked on a contingency fee basis as there was no way we could have paid for these services on our own. Ethan Armstrong, Google User
★★★★★
This lawyer really helped me get compensation for my motorcycle accident case. I know there is no way that I could have gotten anywhere near the amount that Mr. Rosenfeld was able to get to settle my case. Thank you. Daniel Kaim, Avvo User
★★★★★
Jonathan helped my family heal and get compensation after our child was suffered a life threatening injury at daycare. He was sympathetic and in constant contact with us letting us know all he knew every step of the way. We were so blessed to find Jonathan! Giulia, Avvo User
★★★★★
Jonathan did a great job helping my family navigate through a lengthy lawsuit involving my grandmother's death in a nursing home. Through every step of the case, Jonathan kept my family informed of the progression of the case. Although our case eventually settled at a mediation, I really was impressed at how well prepared Jonathan was to take the case to trial. Lisa, Avvo User
★★★★★
Contact Us for a Free Consultation (888) 424-5757
Chicago Office Map