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Be sure to remove this notice and all other notices before
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1 using this document.
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TO: _____________________________ AND THEIR ATTORNEY OF RECORD HEREIN:
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PLEASE TAKE NOTICE that on ____________, 20__, at _______.m. or as soon thereafter
5 as the matter may be heard, in Department ________ of the above-entitled court, located at
6 __________________________, ___________________________will and hereby does move this
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Court:
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1. For an order compelling ___________________________ to provide written,
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verified further responses to Requests for Admission without objections as set forth herein and in
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This motion is brought pursuant to Code of Civil Procedure 2023.010 and 2033.290,
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and is brought by reason of the failure of ____________________, to provide any meaningful
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21 This motion is based upon this notice, the attached memorandum of points and authorities,
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declaration of _____________, and exhibits, the separate statement concurrently served and
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filed with this motion, and upon such oral and documentary evidence as may be presented to the
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Court by _________________ at the time of the hearing.
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27 Dated________________ _______________________________________________
ANY ATTORNEY OR PARTY
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11 statement concurrently herewith containing each request for admission, each response, and basis for
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This motion should be granted because Moving Party has properly completed a good faith
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meet and confer effort regarding further responses to the requests for admission. Despite the fact that
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counsel for Moving Party sent an extensive meet and confer letter to counsel for ______________,
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17 no response, whether it be a letter or a supplemental response, has been received by counsel. The
18 reasons for the objection-only and/or evasive answers are without merit and _________ must be held
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to answer.
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Because Moving Party was forced to bring this motion to compel further responses, Moving
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Party requests sanctions in the amount of $__________________ pursuant to Code of Civil
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23 Procedure 2023.010 and 2033.010 et. seq. As set forth herein, this motion should be granted.
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RELEVANT PROCEDURAL BACKGROUND
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On _______________, Moving Party propounded a complete set of discovery to
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______________ including requests for admission, form and special interrogatories, and a request
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1 for production of documents. (See Ex. A to _________ Declaration). On _____________, Plaintiff
2 provided a written response to the requests for admission, form interrogatories, special interrogatories
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and production demand. (___________ Decl., Ex. B.)
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to-compel-further-answers-to-requests-for-admission-in-
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