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4. All three cases are dependent upon the same administrative record and involve <br />common, if not identical, questions of law and fact. The claims of the named plaintiffs in all <br />three cases were considered together below at the administrative level. <br />5. Consolidation would serve the interests of judicial economy and avoid <br />unnecessary costs and delays, and /or inconsistent determinations on the issues. <br />6. The undersigned has been in contact with the attorney of record for the <br />Colorado Federation of Public Employees who has no objection to the requested <br />consolidation. The undersigned has been unable to reach the counsel of record for Colorado <br />Association of Public Employees and the individual employees named in the Albrecht case <br />nor the individuals named in this action. <br />WHEREFORE, the Defendants request that this matter be consolidated with Colorado <br />Federation of Public Employees, et. al. v. Department of Personnel et. al., Case No. 98 -CV- <br />5863, Courtroom 17, and Albrecht v. Colorado Department of Personnel, Case No. 98 -CV- <br />5935, Courtroom 9, pursuant to C.R.C.P 42(a). <br />GALE A. NORTON <br />Attorney General <br />RICHARD A. WESTFALL <br />Solicitor General <br />PAUL FARLEY <br />Deputy Attorney General <br />DAVID M. KAYE <br />First Assistant Attorney General <br />i'FANN'FTTE WALKER KORNREICH, 17878* <br />Assistant Attorney General <br />State Services Section <br />Attorneys for the Defendants <br />2 <br />