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 FOR AN
Plaintiff, )
ORDER ESTABLISHING ADMISSIONS, AND
)
13 FOR MONETARY SANCTIONS IN THE AMOUNT
vs. )
OF $_________, MEMORANDUM OF POINTS
)
14 AND AUTHORITIES, DECLARATION OF
Any Defendant, )
__________, EXHIBITS
)
15 Defendant. ) DATE: TIME:
) DEPT:
16 )
)
17 )
)
18

19
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24 To view and purchase the California eviction document collection

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containing over 30 sample documents including this sample motion to
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have matters deemed admitted and selling at a huge discount visit:
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- 1 -
NOTICE OF MOTION AND MOTION FOR ORDER ESTABLISHING ADMISSIONS
 1 http://legaldocspro.net/california-eviction-litigation-document-package/
2

3
Be sure to remove these notices before using this document.
4 TO: _____________________________ AND THEIR ATTORNEY OF RECORD HEREIN:
5
PLEASE TAKE NOTICE that on ____________, 20__, at _______.m. or as soon thereafter
6
as the matter may be heard, in Department ________ of the above-entitled court, located at
7

8
__________________________, ___________________________will and hereby does move this

9 Court:

10 1. For an order establishing admissions as to the truth of each matter and the genuineness
11
of each document specified in the first set of requests for admissions served on ______________, and
12
for sanctions in the amount of _________________ against _______________________ for failing
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to provide any responses to the first set of requests for admission.
14

15 This motion is brought pursuant to Code of Civil Procedure 1170.8, 2023.010 and

16 2033.280, and is brought by reason of the failure of ____________________, to provide any

17
responses whatsoever to the first set of requests for admission.
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This motion is based upon this notice, the attached memorandum of points and
19
authorities, the declaration of _____________, and exhibits, and upon such oral and documentary
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21 evidence as may be presented to the Court by _________________ at the time of the hearing.

22
Dated________________ _______________________________________________
23 ANY ATTORNEY OR PARTY
24

25 Note that you MUST personally serve this motion in order for the
26
five days notice. If you serve this motion by mail you MUST give ten
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28 days notice of the hearing.

- 2 -
NOTICE OF MOTION AND MOTION FOR ORDER ESTABLISHING ADMISSIONS
 1 MEMORANDUM OF POINTS AND AUTHORITIES
2 I.
3
PRELIMINARY STATEMENT
4

5 ___________________________________________, (Moving Party) hereby submits their

6
memorandum of points and authorities in support of this motion seeking an order establishing the
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truth of each matters specified in the first set of requests for admissions served on ____________.
8

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This motion should be granted because of the complete failure of ____________ to provide

10 responses to the requests for admission.

11 Because the Moving Party was forced to bring this motion to compel responses, Moving Party
12
requests sanctions in the amount of $__________________ pursuant to Code of Civil Procedure
13
2023.010 and 2033.280 et. seq. As set forth herein, this motion should be granted.
14

15 To purchase the entire document visit:

16

17
https://legaldocspro.myshopify.com/products/sample-motion-
18
to-have-matters-deemed-admitted-in-california-eviction
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NOTICE OF MOTION AND MOTION FOR ORDER ESTABLISHING ADMISSIONS