Kinsey Law Offices 
Notice Of Motion For Order To Compel Answers To Interrogatories
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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 FOR ORDER COMPELLING ANSWERS TO INTERROGATORIES 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
requiring __________ [responding party] to serve a response to
the __________ [number] Set of Interrogatories propounded by
__________ [moving party] to __________ [responding party] and
served on __________ [date]. This motion is made on the grounds
that __________ [specify, for example: __________ (responding
party) has failed to serve a response to __________ (moving
party's) interrogatories, or to seek a protective order, within
the (30 or as the case may be) days allotted by section 2030(h)
of the Code of Civil Procedure. Copies of the __________
[number] Set of Interrogatories with proof of service are
attached as Exhibit _____ and incorporated by reference].
Pursuant to sections 2030(k) 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.

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 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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