When you CPS attorneys out there file a new CPS petition and there is a prior final order in your county on one or more of the kids in the case, at what point do you see the cases are together?

Do you file upfront as a Motion to Modify into the CCJ case or consolidate the cases at a later point in time? Or does it matter?

Depends on what kind of a CCJ it is. If it's a CCJ because there was a previous CPS case, we typically file a motion to modify. If it's a CCJ because of a prior AG case, we file a separate cause and consolidate (if all the same kids) or sever (if different kids in different AG cases) right before final orders so that we don't end up doing all that work and screwing with the cause numbers if we are just going to end up dismissing in the end.

If I know about the prior case (one in the County), I file in that case, regardless of the origin. Otherwise, we do a motion to consolidate as soon as possible. We always file a new petition; I must confess that I had never thought about filing a motion to modify. Recently, we filed a new petition in a prior case and then filed a motion to sever because only one of the three children originally involved in the prior case was involved in our new CPS case.