1 Any Attorney or Party

Any Street
2 Any Town, CA 55555

3 714-555-5555

4 Any Attorney or Party

8 Superior Court of the State of California

9 For the County of_________________

10

11 Any Plaintiff, ) Case No.

)
12 NOTICE OF MOTION AND MOTION TO COMPEL
Plaintiff, )
FURTHER RESPONSES TO REQUESTS FOR
)
13 PRODUCTION OF DOCUMENTS, AND FOR
vs. )
MONETARY SANCTIONS IN THE AMOUNT OF
)
14 $_________, MEMORANDUM OF POINTS AND
Any Defendant, )
AUTHORITIES, DECLARATION OF __________,
)
EXHIBITS
15 Defendant. )
) DATE: TIME:
16 )
DEPT:
)
17 )
)
18

19 TO: NAME AND CAPACITY OF OTHER PARTY AND THEIR ATTORNEY OF

20
RECORD HEREIN:
21
PLEASE TAKE NOTICE that on ____________, _______, at _______.m. or as soon
22
thereafter as the matter may be heard, in Department ________ of the above-entitled court, located at
23

24 NAME AND CAPACITY OF MOVING PARTY will and hereby does move this

25 Court:
26
1. For an order compelling NAME AND CAPACITY OF OTHER PARTY to provide
27
written, verified further written responses to Request for Production of Documents, with document
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 1 production, without objections as set forth herein and in the separate statement filed and served
2 concurrently herewith; and
3
2. For an order of sanctions as against NAME AND CAPACITY OF OTHER PARTY
4
in the amount of $LIST AMOUNT for the preparation and service of meritless objections in making
5

6
initial responses to the request for production of documents.

7 This motion is brought pursuant to Code of Civil Procedure 2023.010 and 2031.310, and is

8 brought by reason of the failure of NAME AND CAPACITY OF OTHER PARTY to provide any
9
meaningful response or to justify the objections stated therein.
10
This motion is based upon this notice, the attached memorandum of points and authorities,
11
declaration of MOVING PARTY, and exhibits, the separate statement concurrently served and
12

13 filed with this motion, and upon such oral and documentary evidence as may be presented to the

14 Court by MOVING PARTY at the time of the hearing.

15

16
Dated________________ _______________________________________________
17 ANY ATTORNEY OR PARTY

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 1 MEMORANDUM OF POINTS AND AUTHORITIES
2 I.
3
PRELIMINARY STATEMENT
4

5 NAME AND CAPACITY OF MOVING PARTY, (Moving Party) hereby submits their
6
memorandum of points and authorities in support of this motion seeking an order compelling
7
OTHER PARTY, (________________) to provide further responses to Requests for Production
8

9
of Documents. Moving Party has complied with California Rule of Court 3.1345 by filing a separate

10 statement concurrently herewith containing each request, each response, and basis for further

11 response.
12
This motion should be granted because Moving Party has properly completed a good faith
13
meet and confer effort regarding further responses to the requests for production of documents.
14
Despite the fact that counsel for Moving Party sent an extensive meet and confer letter to counsel for
15

16 NAME AND CAPACITY OF OTHER PARTY, no response, whether it be a letter or a

17 supplemental response, has been received by counsel. The reasons for the objection-only answers are
18
without merit and OTHER PARTY must be held to answer.
19
To purchase the entire document visit:
20

21
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22

23 to-compel-further-responses-to-requests-for-documents-in-california
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