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This sample demurrer to a first amended complaint in California is filed on the grounds that the first amended complaint fails to state sufficient facts to constitute a cause of action as the causes of action are barred by the statute of limitations. The sample motion contends that the first amended complaint filed by Plaintiff relates to the same transactions that were alleged in the original complaint and asserts the same causes of action, but now, by simply using the delete button on their word processor, Plaintiff purports to have evaded the statute of limitations bar by simply omitting the inconvenient facts from the amended pleading. The sample requests that the general demurrers should be sustained without leave to amend as amendment would be futile. The sample on which this preview is based is 19 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration regarding compliance with the meet and confer requirements of Code of Civil Procedure section 430.41, sample request for judicial notice and proof of service. The author is an entrepreneur and retired litigation paralegal that worked in California and Federal litigation from January 1995 through September 2017 and has created over 300 sample legal documents for sale. Note that the author is NOT an attorney and no guarantee or warranty is provided.