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 _________________

10

11 Any Plaintiff, ) Case No.

)
12 NOTICE OF MOTION AND MOTION TO COMPEL
Plaintiff, )
FURTHER RESPONSES TO REQUESTS FOR
)
13 ADMISSION, AND FOR MONETARY
vs. )
SANCTIONS IN THE AMOUNT OF $_________,
)
14 MEMORANDUM OF POINTS AND
Any Defendant, )
AUTHORITIES, DECLARATION OF __________,
)
EXHIBITS
15 Defendant. )
) DATE: TIME:
16 )
DEPT:
)
17 )
)
18

19
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 1 using this document.
2
TO: _____________________________ AND THEIR ATTORNEY OF RECORD HEREIN:
3

4
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
7
Court:
8
1. For an order compelling ___________________________ to provide written,
9
verified further responses to Requests for Admission without objections as set forth herein and in
10

11 the separate statement filed and served concurrently herewith; and

12 2. For an order of sanctions as against ______________________________,

13
in the amount of $____________ for the preparation and service of knowing incomplete responses to
14
the Requests for Admission, which responses contain mostly boilerplate objections and evasive
15
responses.
16

17
This motion is brought pursuant to Code of Civil Procedure 2023.010 and 2033.290,
18
and is brought by reason of the failure of ____________________, to provide any meaningful
19

20 response or to justify the objections stated therein.

21 This motion is based upon this notice, the attached memorandum of points and authorities,
22
declaration of _____________, and exhibits, the separate statement concurrently served and
23
filed with this motion, and upon such oral and documentary evidence as may be presented to the
24
Court by _________________ at the time of the hearing.
25

26

27 Dated________________ _______________________________________________
ANY ATTORNEY OR PARTY
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 1

2 MEMORANDUM OF POINTS AND AUTHORITIES

3 I.
4
PRELIMINARY STATEMENT
5

6 ___________________________________________, (Moving Party) hereby submits their

7
memorandum of points and authorities in support of this motion seeking an order compelling
8
__________________________, (________________) to provide further responses to Requests
9
for Admission. Moving Party has complied with California Rule of Court 3.1345 by filing a separate
10

11 statement concurrently herewith containing each request for admission, each response, and basis for

12 further response.
13
This motion should be granted because Moving Party has properly completed a good faith
14
meet and confer effort regarding further responses to the requests for admission. Despite the fact that
15
counsel for Moving Party sent an extensive meet and confer letter to counsel for ______________,
16

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
19
to answer.
20

21
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22
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23

24
to-compel-further-answers-to-requests-for-admission-in-
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