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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 _________________

10

11 Any Plaintiff, ) Case No.


)
12 Plaintiff, ) NOTICE OF MOTION AND MOTION TO AMEND
) JUDGMENT TO ADD ____________ JUDGMENT
13 vs. ) DEBTOR ON ALTER EGO THEORY UNDER
) CODE OF CIVIL PROCEDURE SECTION 187;
14 Any Defendant, and DOES 1-5 ) MEMORANDUM OF POINTS AND
) AUTHORITIES; DECLARATION OF
15 Defendants. ) _______________; EXHIBITS
)
16 ) DATE:
) TIME:
17 ) DEPT:
)
18 )
)
19 )
)
20

21
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NOTICE OF MOTION AND MOTION TO AMEND JUDGMENT TO ADD JUDGMENT DEBTOR
1 Be sure to remove this notice and all other notices before
2

3
using this document.
4 TO THE ABOVE-ENTITLED COURT, ALL PARTIES HEREIN, AND THEIR
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ATTORNEYS OF RECORD:
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PLEASE TAKE NOTICE THAT on _____________ at __________ or as soon
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thereafter as the matter may be heard, in Department ________ of the above-entitled Court, located at

9 ________________________ , Plaintiff _____________ will and does move this court pursuant to

10 Code of Civil Procedure 187, for an order amending the judgment entered on ________, to add
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_____________________________________ on the grounds of both alter ego liability and successor
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company theory in that there is such as unity of interest and ownership between the corporation and
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LIST NAME OF PARTY TO BE ADDED AS JUDGMENT DEBTOR, is merely the successor
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15 company to ______________________, who is its equitable owner that the separate personalities of

16 the corporation and the shareholder do not in reality exist, and that failure to do would sanction fraud
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or promote injustice.
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This motion will be based on this notice and on the memorandum of points and authorities
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served and filed herewith, on the declaration of ____________ and exhibits attached thereto, on all
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21 the papers and records of this action and on such other and further oral and/or documentary evidence

22 as may be presented at the hearing on this motion.


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Be sure to modify these paragraphs to suit your individual
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25 situation. Do NOT just use the wording here unless it definitely applies
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to your particular situation.
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NOTICE OF MOTION AND MOTION TO AMEND JUDGMENT TO ADD JUDGMENT DEBTOR
1 Dated________________ _______________________________________________
ANY ATTORNEY OR PARTY
2
Note that you MUST file and serve this motion at least 16 Court
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4 days before hearing if the motion is personally served on all parties, if


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the motion is served by mail you must add five (5) calendar days
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7 additional notice. Court days means Monday through Friday, not


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including Court holidays. This motion should be personally served on
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the individual or party that you are asking to have added as a party to
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12 the Judgment.
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judgment-to-add-alter-ego-as-judgment-debtor-in-california
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NOTICE OF MOTION AND MOTION TO AMEND JUDGMENT TO ADD JUDGMENT DEBTOR

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