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http://freeweeklylegalnewsletter.gr8.com/ and enter your e-mail
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address.
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visit: http://www.scribd.com/LegalDocsPro
4 TO: ALL INTERESTED PARTIES AND THEIR RESPECTIVE ATTORNEYS OF
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RECORD:
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PLEASE TAKE NOTICE THAT on ____________, 20__, at _______.m. or as soon
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thereafter as the matter may be heard, in Department ________ of the above-entitled court, located at
9 ________________________, _________, ____________ will and hereby does move this Court:
10 1. For an order quashing and/or modifying the Deposition Subpoena for Personal
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Appearance and Production of Documents and Things for the deposition currently scheduled for
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__________at ______.M. at _____________________ located at ____________________ to LIST
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HERE HOW YOU WOULD LIKE THE DEPOSITION SUBPOENA QUASHED OR
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15 MODIFIED SUCH AS quashing the Deposition Subpoena for Personal Appearance and Production
16 of Documents and Things (Subpoena) in its entirety on the grounds that the Subpoena does not
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comply with the provisions of Code of Civil Procedure 2020.310(e) in that it does not describe with
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reasonable particularity the matters on which examination is requested, or permitting ________ to be
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deposed over the telephone under the provisions of Code of Civil Procedure 2025.310(a)(b) on the
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21 grounds that attending this deposition would impose a great burden on _________________.
22 2. For an order quashing the request for documents and things on the grounds that
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MODIFY THE WORDING BELOW TO FIT YOUR PARTICULAR SITUATION
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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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individual item or by reasonably particularizing each category of item, and also does not specify the
7 form in which any electronically stored information is to be produced, if a particular form is desired.
8 The Subpoena does not comply with the provisions of Code of Civil Procedure 2020.410(c)
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in that it was served on LIST DATE, which date is less than 15 calendar days before the date of the
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Deposition which is scheduled for LIST DATE OF DEPOSITION.
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The Subpoena does not comply with the provisions of Code of Civil Procedure 2020.410(d
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13 in that it seeks the production of consumer or employee records and is not accompanied either by a
14 copy of the proof of service of the notice to the consumer described in subdivision (e) of Section
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1985.3, or subdivision (b) of Section 1985.6, as applicable, or by the consumers written
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authorization to release personal records described in paragraph (2) of subdivision (c) of Section
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1985.3, or paragraph (2) of subdivision (c) of Section 1985.6, as applicable.
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19 The Subpoena does not comply with the provisions of Code of Civil Procedure 2024.020(a)
20 in that the date for testimony and/or production of business records is less than 30 calendar days
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before the trial date.
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3. For an award of sanctions against_______________, _______ and their attorney of
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record, _______ in the amount of $____ pursuant to Code of Civil Procedure 1987.2(a) and Code
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25 of Civil Procedure 2023.010 for using a discovery method in a manner that does not comply with
26 its specified procedures, and for employing a discovery method in a manner or to an extent that
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causes unwarranted annoyance, embarrassment, or oppression, or undue burden and expense, and for
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records and files of this action, and on such other and further oral and/or documentary evidence as
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Be sure to modify these paragraphs to suit your individual
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10 situation. Do NOT just use the wording here unless it definitely applies
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to your particular situation. Do NOT ask for attorneys fees if you are
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13 not represented by an attorney. Note that you MUST serve every party
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that was served with a copy of the Deposition Subpoena.
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Dated________________ ___________________________________________________
19 ANY ATTORNEY OR PARTY
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24 to-quash-deposition-subponea-in-california
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