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Medical Malpractice Motion 13 - motion to consolidate

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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.

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