1 Any Attorney or Party

Any Street
2 Any Town, CA 55555

3 714-555-5555

4 Any Attorney or Party

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8 Superior Court of the State of California

9 For the County of _________________

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11 Any Plaintiff, ) Case No.
)
12 Plaintiff, ) OPPOSITION TO MOTION TO AMEND
) JUDGMENT TO JUDGMENT DEBTOR ON
13 vs. ) ALTER EGO LIABILITY; MEMORANDUM OF
) POINTS AND AUTHORITIES; DECLARATION OF
14 Any Defendants, and DOES 1-5, inclusive, ) __________, EXHIBITS
)
15 Defendants. ) DATE:
) TIME:
16 ) DEPT:
)
17 )
)
18 )

19
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OPPOSITION TO MOTION TO AMEND JUDGMENT TO ADD JUDGMENT DEBTOR
1 Be sure to remove this notice and all other notices before using
2

3
this document.
4 _____________________________________ herein submits its Opposition to Plaintiff’s
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motion to amend the Judgment entered on ______ to add _____________ as a judgment debtor based
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on alter ego liability on the grounds that:
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1. The motion to amend is not supported by any credible and substantial evidence that

9 would support a finding that ____________ controlled the litigation, conducted discovery or

10 appeared at trial in that the Judgment entered on ________ was obtained by default.
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2. The motion to amend is not supported by any credible and substantial evidence that
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would support a finding of alter ego liability in that LIST HERE THE FACTS SUPPORTING
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YOUR CONTENTION THAT ALTER EGO LIABILITY HAS NOT BEEN SHOWN SUCH AS
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15 NO UNITY OF INTEREST AND OWNERSHIP, NO EVIDENCE OF COMMINGLING,

16 MISREPRESENTATION, OR DIVERSION OF CORPORATE ASSETS, ETC.
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3. The motion to amend is not timely in that the Judgment was entered on ______, and
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the motion to amend was served on ________ which is a period of ___ years since the entry of
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Judgment.
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21 The Opposition shall be based on this Opposition, the attached Memorandum of Points and

22 Authorities, the declaration of __________ and Exhibits attached thereto, on the complete files and
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records of this action, and on such other oral and/or documentary evidence as may be presented at the
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hearing on the Motion.
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27 Dated________________ _______________________________________________
ANY ATTORNEY OR PARTY
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OPPOSITION TO MOTION TO AMEND JUDGMENT TO ADD JUDGMENT DEBTOR
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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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5 to your particular situation. Remember that YOUR OPPOSITION
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MUST BE SERVED AND FILED AT LEAST NINE (9) COURT DAYS
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8 BEFORE THE HEARING. Court days means Monday through
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10
Friday, except for Court holidays. You should serve your opposition by
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personal delivery or overnight mail. See Code of Civil Procedure
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13 Section 1005 for more details.
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To purchase the entire 12 page document visit:
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18 opposition-to-motion-to-amend-judgment-to-add-alter-ego-in-
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20 california
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OPPOSITION TO MOTION TO AMEND JUDGMENT TO ADD JUDGMENT DEBTOR

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