Do NOT ask for attorney’s fees if you are Do NOT just use the wording here unless it definitely appliesĢ7 28 - 2 NOTICE OF MOTION AND MOTION TO COMPEL ATTENDANCE AT DEPOSITON This motion is based upon this notice, the attached memorandum of points and authorities,ĭeclaration of MOVING PARTY, and exhibits, and upon such oral and documentary evidence as may be presented to the Court at the time of the hearing.īe sure to modify these paragraphs to suit your individual This Motion is made upon the grounds that NAME AND CAPACITY OF MOVING PARTY provided proper notice of the deponents’ deposition in a timely manner in accordance withĬode of Civil Procedure § 2025.010 et seq., and NAME AND CAPACITY OF PARTY THATįAILED TO ATTEND THE DEPOSITION refused to appear for their duly noticed deposition. Of Civil Procedure § 2025.450(g)(1), the sum of $LIST AMOUNT in sanctions against NAME ANDĬAPACITY OF PARTY THAT FAILED TO ATTEND THE DEPOSITION.
MOTION TO COMPEL DEPOSITION SAMPLE CODE
The moving party further requests pursuant to Code This motion is brought pursuant to Code of Civil Procedure § 2025.450 on the grounds that NAME AND CAPACITY OF PARTY THAT FAILED TO ATTEND THE DEPOSITION failed to appear for their duly noticed deposition on LIST DATE and did not serve any valid objection on the moving party. TO ATTEND THE DEPOSITION in the amount of $LIST AMOUNT for their blatant failure and refusal to appear at the duly noticed deposition and produce documents. NAME AND CAPACITY OF MOVING PARTY, _will andĢ6 27 28 - 1 NOTICE OF MOTION AND MOTION TO COMPEL ATTENDANCE AT DEPOSITONįor an order compelling NAME AND CAPACITY OF PARTY THAT FAILED TOĪTTEND THE DEPOSITION to attend their deposition, and for production of the documents specified in the deposition notice served upon them and 2.įor an order of sanctions as against NAME AND CAPACITY OF PARTY THAT FAILED or as soon thereafter as the matter may be heard, in Department _ of the above-entitled court, located at
TO: NAME AND CAPACITY OF PARTY THAT FAILED TO ATTEND THE DEPOSITION AND THEIR ATTORNEY OF RECORD HEREIN: PLEASE TAKE NOTICE that on _, 20_, at _.m. NOTICE OF MOTION AND MOTION TO COMPEL ATTENDANCE AT DEPOSITION AND PRODUCTION OF DOCUMENTS, AND FOR MONETARY SANCTIONS IN THE AMOUNT OF $_, MEMORANDUM OF POINTS AND AUTHORITIES, DECLARATION OF _, EXHIBITS DATE: Superior Court of the State of CaliforniaĬase No. Note that the author is NOT an attorney and no guarantee or warranty is provided.Any Attorney or Party Any Street Any Town, CA 55555 The author is a freelance paralegal that has worked in California and Federal litigation since 1995 and has created over300 sample legal documents for sale. The sample contains brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service. This sample opposition to a motion to compel further responses to requests for production of documents in California is made on the grounds that the requests for production of documents are objectionable in that the documents requested clearly do not relate to the claim or defense of the party seeking discovery or of any other party to the action as required by Code of Civil Procedure § 2017.010, and on the further grounds that the requests for production of document are unduly burdensome and oppressive in that the particular documents requests are not specifically described and the categories are not particularized as required by California law, and that the moving party failed to make a reasonable effort to meet and confer.
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