1 Any Attorney or Party

Any Street
2 Any Town, CA 55555

3 714-555-5555

4 Any Attorney or Party

8 Superior Court of the State of California

9 For the County _________________

10

11 Any Plaintiff, ) Case No.

)
12 NOTICE OF MOTION AND MOTION TO COMPEL
Plaintiff, )
FURTHER RESPONSES TO SPECIAL
)
13 INTERROGATORIES, AND FOR MONETARY
vs. )
SANCTIONS IN THE AMOUNT OF $_________,
)
14 MEMORANDUM OF POINTS AND
Any Defendant, )
AUTHORITIES, DECLARATION OF __________,
)
EXHIBITS
15 Defendant. )
) DATE: TIME:
16 )
DEPT:
)
17 )
)
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19 TO: NAME AND CAPACITY OF OTHER PARTY AND THEIR ATTORNEY OF

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RECORD HEREIN:
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PLEASE TAKE NOTICE that on ____________, 20__, at _______.m. or as soon thereafter
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as the matter may be heard, in Department ________ of the above-entitled court, located at
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24 NAME AND CAPACITY OF MOVING PARTY will and hereby do move this

25 Court:
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NOTICE OF MOTION AND MOTION TO COMPEL-SPECIAL INTERROGATORIES
 1 1. For an order compelling NAME AND CAPACITY OF OTHER PARTY to provide
2 written, verified further responses to Special Interrogatories without objections as set forth herein and
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in the separate statement filed and served concurrently herewith; and
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2. For an order of sanctions as against NAME AND CAPACITY OF OTHER PARTY,
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in the amount of $LIST AMOUNT for the preparation and service of knowing incomplete

7 responses to the Special interrogatories, which responses contain mostly boilerplate objections.

8 This motion is brought pursuant to Code of Civil Procedure 2023.010 and 2030.300,
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and is brought by reason of the failure of NAME AND CAPACITY OF OTHER PARTY, to
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provide any meaningful response or to justify the objections stated therein.
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This motion is based upon this notice, the attached memorandum of points and authorities,
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13 declaration of MOVING PARTY, and exhibits, the separate statement concurrently served and

14 filed with this motion, and upon such oral and documentary evidence as may be presented to the
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Court by MOVING PARTY at the time of the hearing.
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17 Dated________________ _______________________________________________
ANY ATTORNEY OR PARTY
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NOTICE OF MOTION AND MOTION TO COMPEL-SPECIAL INTERROGATORIES
 1 MEMORANDUM OF POINTS AND AUTHORITIES
2 I.
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PRELIMINARY STATEMENT
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5 NAME AND CAPACITY OF MOVING PARTY, (Moving Party) hereby submits their
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memorandum of points and authorities in support of this motion seeking an order compelling NAME
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AND CAPACITY OF OTHER PARTY, (________________) to provide further responses to
8

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Special Interrogatories. Moving Party has complied with California Rule of Court 3.1345 by filing a

10 separate statement concurrently herewith containing each interrogatory, each response, and basis for

11 further response.
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This motion should be granted because Moving Party has properly completed a good faith
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meet and confer effort regarding further responses to the interrogatories. Despite the fact that counsel
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for Moving Party sent an extensive meet and confer letter to counsel for NAME AND CAPACITY
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16 OF OTHER PARTY, no response, whether it be a letter or a supplemental response, has been

17 received by counsel. The reasons for the objection-only answers are without merit and NAME AND
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CAPACITY OF OTHER PARTY must be held to answer.
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Because Moving Party was forced to bring this motion to compel further responses, Moving
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Party requests sanctions in the amount of $LIST AMOUNT pursuant to Code of Civil Procedure
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22 2023.010 and 2030.010 et. seq. As set forth herein, this motion should be granted.

23 II.
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RELEVANT PROCEDURAL BACKGROUND
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On LIST DATE, Moving Party propounded a complete set of discovery to NAME AND
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CAPACITY OF OTHER PARTY including form interrogatories, special interrogatories, and a
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28 request for production of documents. (See Ex. A to Declaration). On LIST DATE, OTHER PARTY

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NOTICE OF MOTION AND MOTION TO COMPEL-SPECIAL INTERROGATORIES
 1 provided a written response to the form interrogatories, special interrogatories and production
2 demand. (Decl., Ex. B.)
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compel-further-responses-to-special-interrogatories-for-california
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NOTICE OF MOTION AND MOTION TO COMPEL-SPECIAL INTERROGATORIES