Sample Motion To Compel Further Answers To Requests For Admission in California
Sample Motion To Compel Further Answers To Requests For Admission in California
Sample Motion To Compel Further Answers To Requests For Admission in California
Any Street
2 Any Town, CA 55555
3 714-555-5555
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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
12 further 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 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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