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The parties SHALL complete all nonexpert discovery no later than. November 25, 2020 and all expert discovery no later than January 19, 2021.If all counsel do not agree to consolidate, submit the motion and a memorandum of law showing why the court should consolidate the cases. A consolidated complaint shall be filed within seven days of entry of an order approving this stipulation. 3. Stipulation and Order to Consolidate Cases - Free download as Word Doc (. An order granting or denying all or part of a motion to consolidate must be filed in each case sought to be consolidated. This form can be used to ask the court to consolidate, or join together in one court file, two separate court proceedings or claims. County of Stanislaus, et al. , Case No. -cv-. STIPULATED MOTION TO CONSOLIDATE.