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_________________

10

11 Any Plaintiff, ) Case No.
)
12 NOTICE OF MOTION AND MOTION TO COMPEL
Plaintiff, )
PRODUCTION OF DOCUMENTS BY
)
13 __________; AND FOR MONETARY
vs. )
SANCTIONS IN THE AMOUNT OF $_________,
)
14 MEMORANDUM OF POINTS AND
Any Defendant, )
AUTHORITIES, DECLARATION OF __________,
)
EXHIBITS
15 Defendant. )
) DATE: TIME:
16 )
DEPT:
)
17 )
)
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19 TO: _____________________________ AND THEIR ATTORNEY OF
20
RECORD HEREIN:
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PLEASE TAKE NOTICE that on ____________, _______, 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
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24 __________________________, ___________________________will and hereby do move this

25 Court:
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- 1 -
NOTICE OF MOTION AND MOTION TO COMPEL PRODUCTION OF DOCUMENTS
1 1. For an order compelling ___________________________ to produce the documents
2 requested in the Deposition Subpoena for Production of Business Records served on ___________ on
3
____________________; and
4
2. For an order of sanctions as against __________ in the amount of $_____ for failure to
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produce the documents requested in the Deposition Subpoena for Production of Business Records

7 served on ____________ on _______________.

8 This motion is brought pursuant to Code of Civil Procedure § 2025.480(b) on the grounds
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that as ________________ were served with a Deposition Subpoena for Production of Business
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Records on ____________, with a production date of __________, and _________, failed to produce
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the requested records, by said date, and has still failed to produce the requested records as of the date
12

13 of filing of this motion, the Court should issue an Order compelling ___________, to produce the

14 requested documents, and should order sanctions against ___________, in the amount of $_______
15
for failure to produce the documents requested in the Deposition Subpoena for Production of
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Business Records served on _________________, on _____________.
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This motion is based upon this notice, the attached memorandum of points and authorities,
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19 declaration of _____________, and exhibits, the separate statement concurrently served and

20 filed with this motion, and upon such oral and documentary evidence as may be presented to the
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Court by _________________ at the time of the hearing.
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23 Dated________________ _______________________________________________
ANY ATTORNEY OR PARTY
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NOTICE OF MOTION AND MOTION TO COMPEL PRODUCTION OF DOCUMENTS
1 MEMORANDUM OF POINTS AND AUTHORITIES
2 I.
3
PRELIMINARY STATEMENT
4
The plaintiff in this action is _________________, (“________”). ________ is the assignee of
5

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the original creditor, __________________, (“_________”).

7 Defendant ______________, (“Defendant”) hereby submits their memorandum of points and

8 authorities in support of this motion seeking an order compelling _____________ to produce the
9
documents requested in the Deposition Subpoena for Production of Business Records served on
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_____________ , on _________, and for an order of sanctions as against _____________ , in the
11
amount of $______________ for failure to produce the documents requested in the Deposition
12

13 Subpoena for Production of Business Records served on _____________ , on ____________.

14 A true and correct copy of the Deposition Subpoena for Production of Business Records
15
served on _____________ , on _____________ is attached to the Declaration of ______________ as
16
Exhibit “A” and incorporated herein by reference. A true and correct copy of the Proof of Service is
17
attached as Exhibit “B” to the Declaration of _________________and incorporated herein by
18

19 reference.

20 This motion should be granted because Defendant has properly completed a good faith meet
21
and confer effort to _____________ regarding their failure to respond to the Deposition Subpoena for
22
Production of Business Records served on them. Despite the fact that counsel for Defendant sent an
23
extensive meet and confer letter to _____________, no response, whether it be a letter or a phone
24

25 call, has been received by counsel.

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NOTICE OF MOTION AND MOTION TO COMPEL PRODUCTION OF DOCUMENTS
1 To purchase the entire 12 page document visit:
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https://legaldocspro.myshopify.com/products/sample-motion-to-
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compel-production-of-documents-for-california
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NOTICE OF MOTION AND MOTION TO COMPEL PRODUCTION OF DOCUMENTS

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