![]() ![]() Serve any valid objection as required by Code of Civil Procedure § 2025.410. OTHER PARTY, no response has been received by counsel. Despite the fact that counsel for moving party sent several meet and confer letters to Meet and confer effort regarding the failure of OTHER PARTY to appear for deposition and produceĭocuments. This motion should be granted because the moving party has properly completed a good faith Party in attempting an informal resolution of this matter without the need for judicial intervention. Moving party has herein satisfied that requirement as the declaration of MOVING PARTY and Exhibits attached thereto show the diligence of the moving A motion to compel a party deponent's attendance must be accompanied by a declaration stating facts showing a reasonable, good-faith attempt at informal resolution of each issue presented. MOVING PARTY, (“Moving party”) hereby submits their memorandum of points and authorities in support of this motion seeking an order compelling OTHER PARTY to appear for examination at deposition, and to produce the documents requested in the deposition notice that was served on them on LIST DATE. ![]() _ ANY ATTORNEY OR PARTYħ 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 - 3 NOTICE OF MOTION AND MOTION TO COMPEL ATTENDANCE AT DEPOSITON Do NOT ask for attorney’s fees if you are Do NOT just use the wording here unless it definitely appliesĢ7 28 - 2 NOTICE OF MOTION AND MOTION TO COMPEL ATTENDANCE AT DEPOSITON This motion is based upon this notice, the attached memorandum of points and authorities,ĭeclaration of MOVING PARTY, and exhibits, and upon such oral and documentary evidence as may be presented to the Court at the time of the hearing.īe sure to modify these paragraphs to suit your individual This Motion is made upon the grounds that NAME AND CAPACITY OF MOVING PARTY provided proper notice of the deponents’ deposition in a timely manner in accordance withĬode of Civil Procedure § 2025.010 et seq., and NAME AND CAPACITY OF PARTY THATįAILED TO ATTEND THE DEPOSITION refused to appear for their duly noticed deposition. Of Civil Procedure § 2025.450(g)(1), the sum of $LIST AMOUNT in sanctions against NAME ANDĬAPACITY OF PARTY THAT FAILED TO ATTEND THE DEPOSITION. The moving party further requests pursuant to Code This motion is brought pursuant to Code of Civil Procedure § 2025.450 on the grounds that NAME AND CAPACITY OF PARTY THAT FAILED TO ATTEND THE DEPOSITION failed to appear for their duly noticed deposition on LIST DATE and did not serve any valid objection on the moving party. TO ATTEND THE DEPOSITION in the amount of $LIST AMOUNT for their blatant failure and refusal to appear at the duly noticed deposition and produce documents. NAME AND CAPACITY OF MOVING PARTY, _will andĢ6 27 28 - 1 NOTICE OF MOTION AND MOTION TO COMPEL ATTENDANCE AT DEPOSITONįor an order compelling NAME AND CAPACITY OF PARTY THAT FAILED TOĪTTEND THE DEPOSITION to attend their deposition, and for production of the documents specified in the deposition notice served upon them and 2.įor an order of sanctions as against NAME AND CAPACITY OF PARTY THAT FAILED ![]() or as soon thereafter as the matter may be heard, in Department _ of the above-entitled court, located at TO: NAME AND CAPACITY OF PARTY THAT FAILED TO ATTEND THE DEPOSITION AND THEIR ATTORNEY OF RECORD HEREIN: PLEASE TAKE NOTICE that on _, 20_, at _.m. NOTICE OF MOTION AND MOTION TO COMPEL ATTENDANCE AT DEPOSITION AND PRODUCTION OF DOCUMENTS, AND FOR MONETARY SANCTIONS IN THE AMOUNT OF $_, MEMORANDUM OF POINTS AND AUTHORITIES, DECLARATION OF _, EXHIBITS DATE: Superior Court of the State of CaliforniaĬase No. Any Attorney or Party Any Street Any Town, CA 55555 ![]()
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