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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.


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12 Plaintiff, ) NOTICE OF MOTION AND MOTION FOR
) DIRECTED VERDICT; MEMORANDUM OF
13 vs. ) POINTS AND AUTHORITIES; DECLARATION OF
) ___________; EXHIBITS
14 Any Defendant, and DOES 1-5 )
) TRIAL DATE:
15 Defendants. ) TIME:
) DEPT:
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4 TO _______________________ AND THEIR ATTORNEYS OF RECORD:
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PLEASE TAKE NOTICE THAT, on ___________________ , at ___________________ , or
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as soon thereafter as the matter may be heard, in Dept. __ of this court, located at
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___________________ , STATE WHETHER PLAINTIFF OR DEFENDANT, will, and hereby

9 does, move pursuant to Code of Civil Procedure 630, for an order directing entry of a verdict for the

10 STATE WHETHER PLAINTIFF OR DEFENDANT, and against the STATE WHETHER


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PLAINTIFF OR DEFENDANT on STATE WHETHER ALL ISSUES OR ONLY CERTAIN
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ISSUES AND DESCRIBE ISSUES SUCH AS WHETHER THE PLAINTIFFS CLAIMS
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AGAINST DEFENDANT FOR DAMAGES ARE BARRED AS A MATTER OF LAW BY THE
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15 DOCTRINE OF ASSUMPTION OF THE RISK, ETC.

16 The motion will be made on the grounds that LIST HERE THE LEGAL GROUNDS
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SUCH AS EXAMPLE ONLY: giving to Plaintiff's evidence all the value to which it is legally
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entitled, including all reasonable and logical inferences that may be drawn from that evidence, as a
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matter of law there is no substantial evidence to support a verdict for Plaintiff on any of the claims
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21 asserted by Plaintiff or on Plaintiff's claim for damages based on Defendant's alleged negligence, and

22 thus such evidence is wholly insufficient to warrant submission of the case to the jury.
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The motion will be based on this notice of motion, on the declaration of _________________,
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the attached memorandum of points and authorities, on the records and file in this matter, on such
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portions of the transcript of the trial and supplemental affidavits or declarations and memoranda that
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27 may be filed subsequently in this matter, and on such further oral and documentary evidence as may

28 be presented at the hearing of this motion.

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1 Be sure to modify these paragraphs to suit your individual
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situation. Do NOT just use the wording here unless it definitely applies
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to your particular situation.
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7 Dated________________ _______________________________________________
ANY ATTORNEY OR PARTY
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Note that local rules may require you to serve and file this motion
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11 a certain number of days before the trial date. Be sure to check with
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the clerk in the department where the trial will be held before using this
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motion for directed verdict.
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16 Remember that you cannot move for a directed verdict until both
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parties have completed the presentation of evidence in a jury trial.
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directed-verdict-in-california-under-code-of-civil-procedure-section-
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24 630
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