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Sample Motion To Compel Production of Documents For California
Sample Motion To Compel Production of Documents For California
Any Street
2 Any Town, CA 55555
3 714-555-5555
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NOTICE OF MOTION AND MOTION TO COMPEL PRODUCTION OF DOCUMENTS
1 1. For an order compelling ___________________________ to produce the documents
2 requested in the Deposition Subpoena for Production of Business Records served on ___________ on
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____________________; and
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2. For an order of sanctions as against __________ in the amount of $_____ for failure to
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produce the documents requested in the Deposition Subpoena for Production of Business Records
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8 This motion is brought pursuant to Code of Civil Procedure § 2025.480(b) on the grounds
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that as ________________ were served with a Deposition Subpoena for Production of Business
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Records on ____________, with a production date of __________, and _________, failed to produce
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the requested records, by said date, and has still failed to produce the requested records as of the date
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13 of filing of this motion, the Court should issue an Order compelling ___________, to produce the
14 requested documents, and should order sanctions against ___________, in the amount of $_______
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for failure to produce the documents requested in the Deposition Subpoena for Production of
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Business Records served on _________________, on _____________.
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This motion is based upon this notice, the attached memorandum of points and authorities,
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19 declaration of _____________, and exhibits, the separate statement concurrently served and
20 filed with this motion, and upon such oral and documentary evidence as may be presented to the
21 Court by _________________ at the time of the hearing.
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23 Dated________________ _______________________________________________
ANY ATTORNEY OR PARTY
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NOTICE OF MOTION AND MOTION TO COMPEL PRODUCTION OF DOCUMENTS
1 MEMORANDUM OF POINTS AND AUTHORITIES
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PRELIMINARY STATEMENT
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The plaintiff in this action is _________________, (“________”). ________ is the assignee of
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the original creditor, __________________, (“_________”).
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8 authorities in support of this motion seeking an order compelling _____________ to produce the
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documents requested in the Deposition Subpoena for Production of Business Records served on
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_____________ , on _________, and for an order of sanctions as against _____________ , in the
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amount of $______________ for failure to produce the documents requested in the Deposition
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14 A true and correct copy of the Deposition Subpoena for Production of Business Records
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served on _____________ , on _____________ is attached to the Declaration of ______________ as
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Exhibit “A” and incorporated herein by reference. A true and correct copy of the Proof of Service is
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attached as Exhibit “B” to the Declaration of _________________and incorporated herein by
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19 reference.
20 This motion should be granted because Defendant has properly completed a good faith meet
21 and confer effort to _____________ regarding their failure to respond to the Deposition Subpoena for
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Production of Business Records served on them. Despite the fact that counsel for Defendant sent an
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extensive meet and confer letter to _____________, no response, whether it be a letter or a phone
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NOTICE OF MOTION AND MOTION TO COMPEL PRODUCTION OF DOCUMENTS
1 To purchase the entire 12 page document visit:
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https://legaldocspro.myshopify.com/products/sample-motion-to-
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compel-production-of-documents-for-california
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NOTICE OF MOTION AND MOTION TO COMPEL PRODUCTION OF DOCUMENTS