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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_________________

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11 Any Plaintiff, ) Case No.


)
12 NOTICE OF MOTION AND MOTION TO COMPEL
Plaintiff, )
FURTHER 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 NAME AND CAPACITY OF MOVING PARTY will and hereby does move this

25 Court:
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1. For an order compelling NAME AND CAPACITY OF OTHER PARTY to provide
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written, verified further written responses to Request for Production of Documents, with document
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1 production, without objections as set forth herein and in the separate statement filed and served
2 concurrently herewith; and
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2. For an order of sanctions as against NAME AND CAPACITY OF OTHER PARTY
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in the amount of $LIST AMOUNT for the preparation and service of meritless objections in making
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initial responses to the request for production of documents.

7 This motion is brought pursuant to Code of Civil Procedure 2023.010 and 2031.310, and is

8 brought by reason of the failure of NAME AND CAPACITY OF OTHER PARTY to provide any
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meaningful response or to justify the objections stated therein.
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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, the separate statement concurrently served and
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13 filed with this motion, and upon such oral and documentary evidence as may be presented to the

14 Court by MOVING PARTY at the time of the hearing.


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Dated________________ _______________________________________________
17 ANY ATTORNEY OR PARTY

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1 MEMORANDUM OF POINTS AND AUTHORITIES
2 I.
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PRELIMINARY STATEMENT
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5 NAME AND CAPACITY OF MOVING PARTY, (Moving Party) hereby submits their
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memorandum of points and authorities in support of this motion seeking an order compelling
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OTHER PARTY, (________________) to provide further responses to Requests for Production
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of Documents. Moving Party has complied with California Rule of Court 3.1345 by filing a separate

10 statement concurrently herewith containing each request, each response, and basis for further

11 response.
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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 production of documents.
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Despite the fact that counsel for Moving Party sent an extensive meet and confer letter to counsel for
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16 NAME AND CAPACITY OF OTHER PARTY, no response, whether it be a letter or a

17 supplemental response, has been received by counsel. The reasons for the objection-only answers are
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without merit and OTHER PARTY must be held to answer.
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