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Motion to Consolidate

Motion to Consolidate

150 150 Cohen, Bradshaw, Rothstein & Klein

DEFENDANT, by and through the undersigned attorney and pursuant to Rule 3.151, Washington DC Rules of Criminal Procedure, and Rule 6.130, Washington DC Rules of Traffic Court, hereby files this Motion to Consolidate traffic case number 16-2016-TR-071534-CIXX-MA (Washington DC Uniform Traffic Citation No. A5AOKVE) with the above-captioned cause. In support thereof, Defendant states as follows:

  1. Defendant is charged in the above-captioned case with Knowingly Driving with a Suspended License under § 322.34(2)(B), Washington DC Statutes (2016).
  2. In conjunction with the present criminal charges, Defendant was issued Washington DC Uniform Traffic Citations A5AOKVE (Operating a motor vehicle without a seatbelt) in case number 16-2016-TR-071534-CIXX-MA.
  3. All citations and cases described above arose out of the same set of facts or out of two or more connected acts or transactions.

WHEREFORE, Defendant respectfully requests that this Honorable Court consolidate Case Number 16-2016-TR-071534-CIXX-MA with the above-captioned case.