Sample Motion To Compel Responses To Requests For Production of Documents
Sample Motion To Compel Responses To Requests For Production of Documents
Any Street
2 Any Town, CA 55555
3 714-555-5555
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NOTICE OF MOTION AND MOTION TO COMPEL RESPONSES TO REQUESTS FOR DOCUMENTS
1 1. For an order compelling OTHER PARTY to provide written, verified responses to
2 requests for production of documents, with document production, without objections as set forth
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herein; and
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2. For an order of sanctions as against OTHER PARTY in the amount of $LIST
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AMOUNT for their failure to provide responses to the requests for production of documents.
7 This motion is brought pursuant to Code of Civil Procedure 2023.010 and 2031.300, and is
8 brought by reason of the failure of OTHER PARTY to provide any responses to the requests for
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production of documents.
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This motion is based upon this notice, the attached memorandum of points and authorities,
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declaration of MOVING PARTY, and exhibits, and upon such oral and documentary evidence as
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13 may be presented to the Court by MOVING PARTY at the time of the hearing.
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15 Dated________________ _______________________________________________
16 ANY ATTORNEY OR PARTY
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NOTICE OF MOTION AND MOTION TO COMPEL RESPONSES TO REQUESTS FOR DOCUMENTS
1 MEMORANDUM OF POINTS AND AUTHORITIES
2 I.
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PRELIMINARY STATEMENT
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5 MOVING PARTY, (Moving Party) hereby submits their memorandum of points and
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authorities in support of this motion seeking an order compelling OTHER PARTY,
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(________________) to provide responses to requests for production of documents.
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This motion should be granted because OTHER PARTY has failed to provide any responses
11 Because Moving Party was forced to bring this motion to compel responses, Moving Party
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requests sanctions in the amount of $LIST AMOUNT pursuant to Code of Civil Procedure
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2023.010 and 2031.010 et. seq. As set forth herein, this motion should be granted.
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NOTICE OF MOTION AND MOTION TO COMPEL RESPONSES TO REQUESTS FOR DOCUMENTS