Notice of Motion for Order Compelling Answers at Deposition

NOTICE OF MOTION FOR ORDER COMPELING ANSWERS AT DEPOSITION AND FOR SANCTIONS

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 )

Date:

Time:

Place:

Trial Date:

To , , attorney of record

for , and to

copies of deposition notice or subpoena were served]:

PLEASE TAKE NOTICE that at , on , or as soon

after as the matter can be heard, in or as the case may be] of the

County Superior Court, ,

will move the court for an order requiring to answer certain questions

propounded at oral deposition that refused,

without substantial justification, to answer. This motion is made on the grounds that

refused to answer were within

the scope of permissible discovery; answers to these questions are essential to the preparation of

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,

will also seek monetary sanctions of $ against

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

posed at deposition.

The motion will be based on this notice of motion, the attached memorandum of points and

authorities, the declaration of , the

Statement of Questions and Responses in Dispute, the transcript of

deposition, the record and files of this case, and any further oral or documentary evidence

introduced at the hearing of this motion.

DATED: