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Motion 6-Consolidate Cases in Car Accident Case

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Plaintiffs' Motion to Consolidate

NOW COME the plaintiffs, ________________ and ___________, by and through their attorneys, _____________________., and pursuant to 735 ILCS 5/2-1006, move this Honorable Court to consolidate William Thomas v. Rogelio Iniguez and Gerardo Jiminez, 97 L 10146, into 96 L 12414, and in support thereof, state as follows:

1. That the above actions arise from an automobile accident which occurred on August 4, 1996. That plaintiff, STARR SINKO, is alleging that she sustained personal injuries as a result of said automobile accident.

2. That plaintiffs in each action allege that the defendant, Rogelio Iniguez, was guilty of negligence in the operation and use of a motor vehicle owned by Gerardo Jiminez.

3. That inasmuch as these cases arise out of the same occurrence, consolidation for the purposes of discovery and pretrial proceedings would be an aid to convenience and in the interest of judicial economy.

4. That consolidation of these cases will not result in prejudice to any substantial rights of any of the parties.

WHEREFORE, plaintiffs, _____________ and ___________, respectfully request this Court to enter an Order consolidating the above-entitled actions for purposes of discovery and pretrial proceedings.

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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. Michonne Proulx
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
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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
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