Fill and Sign the Notice of Motion for Order Compeling Answers at Deposition and Form

-1- 1 2 34 5 6 7 8 9 101112 13 1415 16 17 18 19 20 21 22 2324 25 262728 (Name, Address Of Party or attorney) _____________________________ _____________________________ _____________________________ State Bar No: __________________ (____) _____ - _________________ Attorney for _______ (Or "In Pro Per") SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF ________ PLAINTIFF(S) NAMES )CASE NO.: _______Plaintiffs ) ) v) ) DEFENDANT(S) NAMES ) Defendants) ) ---------------------------------------------------------------- NOTICE OF MOTION FOR ORDER COMPELING ANSWERS AT DEPOSITION AND FOR SANCTIONS Date: ______ Time: ______ Place: ______ Trial Date: _____ To __________ [name of deponent], __________ [deponent's attorney], attorney of record for __________ [deponent], and to __________ [names of other parties or attorneys on whom copies of deposition notice or subpoena were served]:PLEASE TAKE NOTICE that at __________ [time], on __________[date], or as soon after as the matter can be heard, in __________ [Department _____ or as the case may be] of the __________ County Superior Court, __________ [court address], __________ [moving party] -2- 1 2 34 5 6 7 8 9 101112 13 1415 16 17 18 19 20 21 22 2324 25 262728 will move the court for an order requiring __________ [deponent] to answer certain questions propounded at __________ [his or her] oral deposition that __________ [he or she] refused, without substantial justification, to answer. This motion is made on the grounds that __________ [specify, for example: the questions that __________ (deponent) refused to answer were within the scope of permissible discovery; answers to these questions are essential to the preparation of __________ (moving party's) case. __________(Deponent's) refusal to answer the questions listed in the attached statement of questions and responses in dispute was without substantial justification]. Pursuant to sections 2025(o) and 2023(b)(1) of the Code of Civil Procedure, __________ [moving party] will also seek monetary sanctions of $_____ against __________ [deponent and his or her attorney or as the case may be] for reasonable attorney fees and costs incurred in bringing this motion. Such sanctions are sought on the ground that there is not substantial justification for __________ [deponent's] conduct in refusing to answer the questions posed at deposition.The motion will be based on this notice of motion, the attached memorandum of points and authorities, the declaration of __________ [name of witness or attorney or as the case may be], the Statement of Questions and Responses in Dispute, the transcript of __________ [deponent's] deposition, the record and files of this case, and any further oral or documentary evidence introduced at the hearing of this motion. DATED: __________________.__________________________ [Signature] Attorney for __ ___________ [moving party]