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this document.
4 TO _______________________ AND THEIR ATTORNEYS OF RECORD:
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NOTICE IS HEREBY GIVEN that, on INSERT DATE OF HEARING at INSERT TIME
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OF HEARING or as soon thereafter as the matter may be heard, in Dept/Division INSERT
8 DEPARTMENT OR DIVISION of the above entitled court located at INSERT FULL STREET
9 ADDRESS OF COURT, INSERT YOUR NAME AND YOUR PARTY CAPACITY SUCH AS
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PLAINTIFF OR DEFENDANT will move pursuant to Code of Civil Procedure 663 for an order:
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1. To set aside and vacate the judgment entered on LIST DATE JUDGMENT
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ENTERED;
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15 2. To amend and correct the statement of decision filed in this action on LIST DATE
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STATEMENT OF DECISION WAS FILED; and
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OR
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2. To correct the judgment or decree of the court that is not consistent with the special
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20 verdict, rendered by the jury on LIST DATE SPECIAL VERDICT RENDERED; and
26 is incorrect and/or erroneous in that it is not consistent with and/or supported by the facts. These
27 errors have materially affected the substantial rights of LIST YOUR NAME AND PARTY
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1 CAPACITY entitling him/her to a different judgment in that STATE FACTS SHOWING HOW
2 YOU WERE DEPRIVED OF A FAIR TRIAL.
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The following legal bases for the decision, for the reasons specified, are incorrect and/or
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erroneous and not consistent with and/or supported by the facts:
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1. LIST HERE THE ERRONEOUS OR INCORRECT LEGAL BASES AND
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19 The motion will be made on the ground that the STATE JUDGMENT OR DECREE AS
20 APPROPRIATE IN YOUR CASE is not consistent with or supported by the special verdict of the
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jury. This error materially affected the substantial rights of LIST YOUR NAME AND PARTY
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CAPACITY entitling him/her to a different judgment in that STATE THE FACTS SHOWING
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HOW YOU WERE DEPRIVED OF A FAIR TRIAL.
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26 consistent with or supported by the special verdict of the jury that stated the following:
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INCORPORATE VERMATIM A COPY OF THE JURYS SPECIAL VERDICT. STATE
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1 JUDGMENT OR DECREE AS APPROPRIATE IN YOUR CASE is not consistent with or
2 supported by the special verdict of the jury because:
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1. STATE THE REASONS WHY THE JUDGMENT OR DECREE IS NEITHER
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CONSISTENT NOR SUPPORTED BY THE SPECIAL VERDICT.
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The following LIST JUDGMENT OR DECREE HERE AS APPROPRIATE should be
7 entered:
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https://legaldocspro.myshopify.com/products/sample-motion-
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