Fill and Sign the Notice of Motion to Compel Further Answers to Requests 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 TO COMPEL FURTHER ANSWERS TO REQUESTS FOR ADMISSION AND FOR SANCTIONS Date: ______ Time: ______ Place: ______ Trial Date: _____ To __________ [name of responding party], __________ [responding party's attorney], attorney of record for __________ [responding party], and to __________ [names of other parties or attorneys appearing in action]: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 compelling __________ [responding party] to provide further responses to the __________ [number] Set of Requests for Admission propounded by __________ [moving party] to __________[responding party] on __________ [date]. This motion is made on the grounds that __________ [specify, for example: __________(responding party) provided evasive, incomplete answers to Requests 4, 10, 15, 17, and 30-35 in the __________ (number) Set of Requests]. The requests, responses at issue, and reasons for compelling further responses are set out in the attached Statement of Requests and Responses in Dispute. Pursuant to sections 2033(l) and 2023(b)(1) of the Code of Civil Procedure, __________ [moving party] will also seek monetary sanctions of $__________ against __________ [responding party 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 __________ [responding party's] conduct in __________[specify conduct for which sanctions are sought].This motion will be based on the 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 Requests and Responses in Dispute, 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]