SUPERIOR COURT OF THE STATE
OF CALIFORNIA
COUNTY OF ________
- [PLAINTIFF(S) NAMES]
- Plaintiffs,
- v.
-
- [DEFENDANT(S) NAMES]
- Defendants
-
-
- ________________________________
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- CASE NO: _______
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- NOTICE OF MOTION FOR ORDER COMPELLING FURTHER ANSWERS
TO INTERROGATORIES AND FOR SANCTIONS
-
- Date: ______
- Time: ______
- Place: ______
- Trial Date: _____
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To __________ [name of responding party],
__________ [responding
party's attorney], attorney of record for __________ [responding
party], and to __________ [names of other parties or attorneys
appearing in action]:
PLEASE TAKE NOTICE that at __________
[time], on __________
[date], or as soon after as the matter can be heard, in
__________ [Department _____ or as the case may be] of the
__________ County Superior Court, __________ [court address],
__________ [moving party] will move the court for an order
requiring __________ [responding party] to provide further
responses to interrogatories propounded by __________ [moving
party]. This motion is made on the grounds that __________
[specify, for example: __________ (responding party) provided
evasive, incomplete answers to Interrogatories 5-10, 15, 17,
and
20-26]. The interrogatories at issue, __________ [responding
party's] responses to them, and the reasons for compelling
further response are set out in the attached Statement of
Interrogatories and Responses in Dispute. Pursuant to sections
2030(l) and 2023(b)(1) of the Code of Civil Procedure,
__________ [moving party] will also seek monetary sanctions of
$__________ against __________ [responding party and his or her
attorney or as the case may be] for reasonable attorney fees
and
costs incurred in bringing this motion. Such sanctions are
sought on the ground that there is not substantial justification
for __________ [responding party's] conduct in __________
[conduct for which sanctions are sought, for instance: failing
to provide complete answers to the interrogatories posed].
This motion will be based on the notice
of motion, the
attached memorandum of points and authorities, the declaration
of __________ [name of witness or attorney or as the case may
be], the Statement of Interrogatories and Responses in Dispute,
the record and files of this case, and any further oral or
documentary evidence introduced at the hearing of this motion.
Dated __________.
____________________
[Signature]
Attorney for __________ [moving party]
