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Sample Motion To Compel Responses To Requests For Production of Documents

This sample motion to compel responses to requests for production of documents in California is used when a party has served requests for production of documents but has received no responses. The motion contains a memorandum of points and authorities with citations to case law and statutory authority, a sample declaration and proof of service by mail. The author is a freelance paralegal that has worked in California and Federal litigation since 1995 and has used this sample for many years. Note that the author is NOT an attorney and no guarantee or warranty is provided.

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Stan Burman
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50% found this document useful (2 votes)
11K views

Sample Motion To Compel Responses To Requests For Production of Documents

This sample motion to compel responses to requests for production of documents in California is used when a party has served requests for production of documents but has received no responses. The motion contains a memorandum of points and authorities with citations to case law and statutory authority, a sample declaration and proof of service by mail. The author is a freelance paralegal that has worked in California and Federal litigation since 1995 and has used this sample for many years. Note that the author is NOT an attorney and no guarantee or warranty is provided.

Uploaded by

Stan Burman
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOC, PDF, TXT or read online on Scribd
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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, )
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 )
)
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19 TO: NAME AND CAPACITY OF OTHER PARTY AND THEIR ATTORNEY OF


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RECORD HEREIN:
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PLEASE TAKE NOTICE that on ____________, _______, at _______.m. or as soon
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thereafter as the matter may be heard, in Department ________ of the above-entitled court, located at
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24 __________________________, MOVING PARTY will and hereby does move this

25 Court:
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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
5

6
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

10 whatsoever to the requests for production of documents.

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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15 To purchase the entire 10 page document visit:


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https://legaldocspro.myshopify.com/products/sample-motion-to-
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NOTICE OF MOTION AND MOTION TO COMPEL RESPONSES TO REQUESTS FOR DOCUMENTS

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