Case No. 98CV6048 Motion to Consolidate Pursuant to C.R.C.P. 42(A) August 1998

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DISTRICT COURT, CITY AND COUNTY OF DENVER, COLORADO Case No. 98 CV 6048, Courtroom 4 MOTION TO CONSOLIDATE PURSUANT TO C.R.C.P. 42(A) JANIS ILLIAN, et. al., Plaintiffs, V. COLORADO DEPARTMENT OF PERSONNEL and ANDRE PETTIGREW, in his official capacity as Executive Director of the Department of Personnel, Defendants. Defendants, the Colorado Department of Personnel ( "Department ") and Andr6 Pettigrew, in his official capacity as Executive Director ( "Director ") of the Department, through the Attorney General for the State of Colorado and by the undersigned Assistant Attorney General, hereby move to consolidate this matter with two other cases before this Court, and as grounds therefor, state: 1. This matter is for judicial review of an agency action, pursuant to §§ 24 -4- 106(4) and 24- 50- 104(4)(d)(I), 7 C.R.S. (1997), concerning a systems maintenance study pertaining to an assignment of pay grades to class series. The class series at issue is the Physical Science Researcher /Scientist (PSR/S) class series affected by a Notice of Proposed System Changes, JEL 98 -11, issued on March 20, 1998. 2. The Plaintiffs in this action are all classified state employees holding positions in the PSR/S class series. This action is for review of the Director's decision, dated June 24, 1998, which upheld JEL 98 -11. (copy attached to the Complaint). 3. Two other actions, Colorado Federation of Public Employees, et. al. v. Department of Personnel et. al., Case No. 98 -CV -5863, Courtroom 17, and Albrecht v. Colorado Department of Personnel, Case No. 98 -CV -5935, Courtroom 9, have been filed on behalf of other individual state employees employed in the PSR/S class series. The individuals named in those two actions also appealed the Department's issuance of JEL 98 -11 to the Director and also seek judicial review of the Director's decision of June 24, 1998 upholding the proposed changes.