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776

Consolidation for Trial of Issues in Civil and Criminal Contempt Proceedings

Consolidation for trial of issues germane to civil and criminal actions involving the same transaction or series of transactions is permitted when the parties stipulate to such. In addition, consolidation without stipulation is generally allowed and appellate courts have not reversed except when there has been substantial prejudice. See United States v. United Mine Workers of America, 330 U.S. 258, 298-300 (1947); Mitchell v. Fiore, 470 F.2d 1149, 1153 (3d Cir. 1972), cert. denied, 411 U.S. 938 (1973).