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 _________________

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11 Any Plaintiff, ) Case No.

)
12 NOTICE OF MOTION AND MOTION TO COMPEL
Plaintiff, )
RESPONSES TO SPECIAL INTERROGATORIES,
)
13 AND FOR MONETARY SANCTIONS IN THE
vs. )
AMOUNT OF $_________, MEMORANDUM OF
)
14 POINTS AND AUTHORITIES, DECLARATION OF
Any Defendant, )
__________, EXHIBITS
)
15 Defendant. ) DATE: TIME:
) DEPT:
16 )
)
17 )
)
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19 TO: NAME AND CAPACITY OF OTHER PARTYAND THEIR ATTORNEY OF

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RECORD HEREIN:
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PLEASE TAKE NOTICE that on _________________, at _______.m. or as soon thereafter
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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

25 hereby does move this Court:

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1. For an order compelling OTHER PARTY to provide written,
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verified responses to special interrogatories without objections as set forth herein; and
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NOTICE OF MOTION AND MOTION TO COMPEL RESPONSES TO INTERROGATORIES
 1 2. For an order of sanctions as against OTHER PARTY, in the amount of $LIST
2 AMOUNT for failing to provide any responses to the special interrogatories.
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This motion is brought pursuant to Code of Civil Procedure 2023.010 and 2030.290,
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and is brought by reason of the failure of OTHER PARTY, to provide any responses.
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This motion is based upon this notice, the attached memorandum of points and authorities,

7 declaration of MOVING PARTY, and exhibits, , and upon such oral and documentary evidence as

8 may be presented to the Court by MOVING PARTY at the time of the hearing.
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10 Dated________________ _______________________________________________
ANY ATTORNEY OR PARTY
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NOTICE OF MOTION AND MOTION TO COMPEL RESPONSES TO INTERROGATORIES
 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 responses to special interrogatories.
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This motion should be granted because of the complete failure of OTHER PARTY to provide

10 responses to the special interrogatories.

11 Because the Moving Party was forced to bring this motion to compel responses, Moving Party
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requests sanctions in the amount of $LIST AMOUNT pursuant to Code of Civil Procedure
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2023.010 and 2030.290 et. seq. As set forth herein, this motion should be granted.
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II.
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16 RELEVANT PROCEDURAL BACKGROUND

17 On LIST DATE, Moving Party propounded a complete set of discovery to OTHER PARTY
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including form interrogatories, special interrogatories, and a request for production of documents.
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(See Ex. A to _________ Declaration).
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OTHER PARTY has failed to provide any responses to the special interrogatories. Counsel
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22 for Moving Party sent a letter to OTHER PARTY on DATE requesting that responses be provided

23 within ten days. No response was received. (See Ex. B to _________ Declaration).
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NOTICE OF MOTION AND MOTION TO COMPEL RESPONSES TO INTERROGATORIES
 1 III.
2 ARGUMENT
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A. THE COURT IS AUTHORIZED TO GRANT THIS MOTION TO COMPEL
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RESPONSES BECAUSE OF _____________S BLATANT FAILURE TO COMPLY
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WITH THE DISCOVERY ACT

7 To purchase the entire 11 page document visit:

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https://legaldocspro.myshopify.com/products/sample-motion-to-
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compel-responses-to-special-interrogatories-for-california
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NOTICE OF MOTION AND MOTION TO COMPEL RESPONSES TO INTERROGATORIES