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 _________________

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11 Any Plaintiff, ) Case No.

)
12 Plaintiff, ) OBJECTION TO DEPOSITION SUBPOENA FOR
vs. ) PRODUCTION OF BUSINESS RECORDS
13 )
) DATE:
14 Any Defendants, and DOES 1-5, inclusive, ) TIME:
) PLACE:
15 Defendants. )
)
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)
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)
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28 TO: ALL INTERESTED PARTIES AND THEIR RESPECTIVE ATTORNEYS OF

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OBJECTION TO DEPOSITION SUBPOENA FOR PRODUCTION OF BUSINESS RECORDS

 1 RECORD:
2 PLEASE TAKE NOTICE THAT NAME AND CAPACITY OF OBJECTING PARTY
3
through its attorney of record, hereby submits their Objection to the Deposition Subpoena for
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Production of Business Records served by NAME AND CAPACITY OF PARTY THAT SERVED
5

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THE DEPOSITION SUBPOENA on the grounds that

7 USE THE WORDING BELOW FOR A DEPOSITION SUBPOENA THAT REQUESTS ONLY

8 ATTENDANCE AND TESTIMONY AT A DEPOSITION FOR AN ORGANIZATION SUCH

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AS A CORPORATION
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The Subpoena does not comply with the provisions of Code of Civil Procedure 2020.220(a)
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in that it does not allow the objecting party sufficient time to have a reasonable opportunity to locate
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13 and produce any designated business records, documents, or tangible things and a reasonable time to

14 travel to the deposition location.

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The Subpoena does not comply with the provisions of Code of Civil Procedure 2020.310(e)
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in that it does not describe with reasonable particularity the matters on which examination is
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requested.
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OBJECTION TO DEPOSITION SUBPOENA FOR PRODUCTION OF BUSINESS RECORDS