Kinsey Law Offices 
Notice Of Motion To Compel Further Answers To Requests For Admissions
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    (Name, Address Of Party or attorney)
    ____________
    ____________
    ____________
    State Bar No: ______
    (____) _____ - ________
    Attorney for _______ (Or "In Pro Per")

 

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF ________

 

[PLAINTIFF(S) NAMES]
Plaintiffs,

 

v.
 
[DEFENDANT(S) NAMES]
Defendants
 
 
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CASE NO: _______
 
NOTICE OF MOTION TO COMPEL FURTHER ANSWERS TO REQUESTS FOR ADMISSION AND FOR SANCTIONS
 
Date: ______
Time: ______
Place: ______
Trial Date: _____

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
compelling __________ [responding party] to provide further
responses to the __________ [number] Set of Requests for
Admission propounded by __________ [moving party] to __________
[responding party] on __________ [date]. This motion is made on
the grounds that __________ [specify, for example: __________
(responding party) provided evasive, incomplete answers to
Requests 4, 10, 15, 17, and 30-35 in the __________ (number) Set
of Requests]. The requests, responses at issue, and reasons for
compelling further responses are set out in the attached
Statement of Requests and Responses in Dispute. Pursuant to
sections 2033(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 __________
[specify conduct for which sanctions are sought].

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 Requests 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]

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