(a) Motions to Amend.
(1) No plaintiff shall have leave to amend a pleading, unless in matters of form, after a default until the defendant has been provided with notice and an opportunity to be heard, to show cause why the amendment should not be allowed.
(2) Amendments in matters of form will be allowed or ordered, as of course, on motion; but, if the defect or want of form be shown by the adverse party, the order to amend will be made on such terms as justice may require.
(3) Amendments in matters of substance may be made on such terms as justice may require.
(4) Amendments may be made to the Complaint or Answer upon the order of the court, at any time and on such terms as may be imposed.
(b) Motions to Consolidate . Whenever a