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Superior Court of the State of California
9 For the County of _________________
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23 Court for terminating sanctions by an order striking defendants answer and rendering judgment by
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default against defendant ___________________based on defendants willful failure to comply with
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this Courts numerous orders compelling responses to plaintiffs interrogatory on defendant.
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This motion is made on the grounds that, per Code of Civil Procedure 2030.290(c),
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NOTICE OF MOTION AND MOTION FOR TERMINATING SANCTIONS
1 Defendant has demonstrated a consistent persistent and willful noncompliance in plaintiffs
2 discovery efforts, engaging in repeated and egregious violations of the discovery laws that impair
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plaintiffs rights and threaten the integrity of the judicial process.
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This motion is based on this notice, the pleadings, records, and files in this action; the
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attached memorandum of points and authorities, the supporting declaration of _____________ and
7 exhibits attached thereto, and any further oral and/or documentary evidence presented at the hearing.
9 Dated________________ _______________________________________________
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ANY ATTORNEY OR PARTY
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NOTICE OF MOTION AND MOTION FOR TERMINATING SANCTIONS
1 MEMORANDUM OF POINTS AND AUTHORITIES
2 I.
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PRELIMINARY STATEMENT
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Plaintiff filed a complaint alleging defamation of character against defendant in
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_____________. Plaintiff seeks terminating sanctions against defendant for his willful, fourteen
7 month long abuse of the discovery process and utter failure to participate in plaintiffs discovery
8 efforts and advancement of the case. To date, Defendant has ignored a subpoena, plaintiffs first
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interrogatory on defendant, and four court orders compelling compliance with the two discovery
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documents, and utterly ignores plaintiffs attempts to meet and confer.
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NOTICE OF MOTION AND MOTION FOR TERMINATING SANCTIONS
1 Pursuant to C.C.P. 2023.010(d), (g), and (i), failing to respond or to submit to authorized
2 methods of discovery, disobeying a court order to provide discovery, and failing to confer are
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all misuses of the discovery process.
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To purchase the entire 17 page document please visit:
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https://legaldocspro.myshopify.com/products/sample-motion-for-
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NOTICE OF MOTION AND MOTION FOR TERMINATING SANCTIONS