Several Ohio courts have found error in such a consolidation absent a formal consolidation order prior to the hearing or some other form of notice that the trial court intends to proceed to the merits at the hearing. See id. at ¶ 10, citing Turoff v. Stefanac, 16 Ohio App.3d 227, 475 N.E.2d 189 (8th Dist.1984); Gionino's Pizzeria Inc. v. Reynolds, 7th Dist. Carroll No. 20 CA 0940, 2021-Ohio-1289, ¶ 44. This aligns with the U.S. Supreme Court's interpretation of the near-identical federal rule and its relationship to due process.