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 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:
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)
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)
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TO: _____________________________ AND THEIR ATTORNEY OF
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RECORD HEREIN:

21 PLEASE TAKE NOTICE that on ____________, 20__, at _______.m. or as soon thereafter

22 as the matter may be heard, in Department ________ of the above-entitled court, located at
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__________________________, ___________________________will and hereby do move this
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Court:
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1. For an order establishing admissions as to the truth of each matter specified in the
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27 first set of requests for admissions served on _________________________________, and for

28 sanctions in the amount of _________________ against _______________________ for failing to

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NOTICE OF MOTION AND MOTION FOR ORDER ESTABLISHING ADMISSIONS
 1
provide any responses to the first set of requests for admission.
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3 This motion is brought pursuant to Code of Civil Procedure 2023.010 and 2033.280

4 and is brought by reason of the failure of ____________________, to provide any responses.

5 This motion is based upon this notice, the attached memorandum of points and
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authorities, the declaration of _____________, and exhibits, and upon such oral and documentary
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evidence as may be presented to the Court by _________________ at the time of the hearing.
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Dated________________ _______________________________________________
10 ANY ATTORNEY OR PARTY

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NOTICE OF MOTION AND MOTION FOR ORDER ESTABLISHING ADMISSIONS
 1 MEMORANDUM OF POINTS AND AUTHORITIES
2 I.
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PRELIMINARY STATEMENT
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5 ___________________________________________, (Moving Party) hereby submits their

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memorandum of points and authorities in support of this motion seeking an order eastablishing the
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truth of each matters specified in the first set of requests for admissions served on ____________.
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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
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requests sanctions in the amount of $__________________ pursuant to Code of Civil Procedure
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2023.010 and 2033.280 et. seq. As set forth herein, this motion should be granted.
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15 To purchase the entire 10 page document visit:

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https://legaldocspro.myshopify.com/products/sample-motion-to-have-
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NOTICE OF MOTION AND MOTION FOR ORDER ESTABLISHING ADMISSIONS