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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.


)
12 Plaintiff, ) NOTICE OF DEMURRER AND DEMURRER TO
) COMPLAINT; MEMORANDUM OF POINTS AND
13 vs. ) AUTHORITIES; DECLARATION OF
) ______________ REGARDING COMPLIANCE
14 Any Defendant, and DOES 1-5 ) WITH MEET AND CONFER REQUIREMENTS OF
) CODE OF CIVIL PROCEDURE 430.41
15 Defendants. )
)
16 ) DATE:
) TIME:
17 ) DEPT:
)
18 )
)
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20 NOTICE OF DEMURRER AND DEMURRER TO COMPLAINT BY DEFENDANT


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________________________________________
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23 TO: ALL PARTIES AND THEIR ATTORNEYS OF RECORD:


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PLEASE TAKE NOTICE that on _______________ at ___________. in Department ___of
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the above entitled court, located at ____________________________________________,
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Defendant, _________________________, will and hereby does move the Court for an order
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28 sustaining general demurrers to the first, second, third and fourth causes of action in Plaintiffs

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NOTICE OF DEMURRER AND DEMURRER TO COMPLAINT
1
Complaint.
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3 The moving party has complied with the meet and confer requirements of Code of Civil

4 Procedure 430.41 as shown by the attached declaration.


5 This demurrer is made pursuant to Code of Civil Procedure 430.10(e) on the grounds that
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the first, second, third and fourth causes of action in Plaintiffs Complaint fail to state sufficient facts
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to constitute causes of action as Plaintiff lacks standing to assert any claims against Moving
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Defendants in that _________________________. Set forth reasons that Plaintiff lacks standing

10 to sue.

11 The Demurrer shall be based on this notice of demurrer and the attached demurrer, the
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attached memorandum of points and authorities, the attached declaration of ________ regarding
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compliance with the meet and confer requirements of Code of Civil Procedure 430.41, on the
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complete files and records of this action, and on such other oral and/or documentary evidence as may
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16 be presented at the hearing on the Motion.

17 Dated________________ _______________________________________________
ANY ATTORNEY OR PARTY
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NOTICE OF DEMURRER AND DEMURRER TO COMPLAINT
1 DEMURRER TO PLAINTIFFS FIRST AMENDED COMPLAINT
2 This demurrer is made pursuant to Code of Civil Procedure 430.10 on the grounds that the
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first, second, third and fourth causes of Action of the First Amended Complaint fail to state facts
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sufficient to constitute a cause of action against the Moving Defendants.
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Moving Defendants hereby generally demur to Plaintiffs First Amended Complaint on each

7 of the following grounds:

8 DEMURRER TO FIRST CAUSE OF ACTION:


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1. The first cause of action fails to state facts sufficient to constitute a cause of action as
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Plaintiff lacks standing to assert any claims against Moving Defendants in that
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_________________________________________________________________________________
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13 ________________________________________________.

14 DEMURRER TO SECOND CAUSE OF ACTION:


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2. The second cause of action fails to state facts sufficient to constitute a cause of
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action as Plaintiff lacks standing to assert any claims against Moving Defendants in that
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_________________________________________________________________
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19 ________________________________________________.

20 DEMURRER TO THIRD CAUSE OF ACTION:


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3. The third cause of action fails to state facts sufficient to constitute a cause of
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Action as Plaintiff lacks standing to assert any claims against Moving Defendants in that
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_________________________________________________________________________________
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25 _______________________________________.

26 DEMURRER TO FOURTH CAUSE OF ACTION:


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4. The fourth cause of action fails to state facts sufficient to constitute a cause of
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NOTICE OF DEMURRER AND DEMURRER TO COMPLAINT
1 action for conversion as Plaintiff lacks standing to assert any claims against Moving Defendants in
2 that _________________________________________________________________________
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_______________________________________.
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8 complaint-for-lack-of-standing-in-california
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NOTICE OF DEMURRER AND DEMURRER TO COMPLAINT