The document is an opposition to a motion for summary judgment filed by the cross-complainant in a legal case regarding allegations including breach of contract, fraud, and declaratory relief. The cross-complainant argues that there are triable issues of material fact, denying the allegations by the plaintiff and asserting that the claims should proceed to be heard on their merits. The document includes references to supporting declarations and related exhibits.

1. 1 1ANY ATTORNEY
LAW OFFICES OF ANY ATTORNEY
2 12345 ANY STREET
3 ANY TOWN, CA 55555
213-555-5555
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Attorney for Defendants/Cross-Complainants
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
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FOR THE COUNTY OF LOS ANGELES
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13 ANY PLAINTIFF, ) CASE NO.
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14 Plaintiff, )
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v. ) OPPOSITION TO MOTION FOR
16 ) SUMMARY JUDGMENT;
ANY DEFENDANTS, ) MEMORANDUM OF POINTS
17 ) AND AUTHORITIES;
Defendants. ) SEPARATE STATEMENT OF
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) UNDISPUTED MATERIAL FACTS;
19 ____________________________________) DECLARATION OF ________
) EXHIBITS
20 AND RELATED CROSS-ACTIONS )
) DATE:
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) TIME:
22 ) DEPT:
____________________________________)
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24 To subscribe to my FREE California weekly legal newsletter visit
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27 address. To purchase and download the entire demurrer visit:
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OPPOSITION TO MOTION FOR SUMMARY JUDGMENT

2. 1 http://www.scribd.com/doc/27153403/Sample-Opposition-to-Motion-
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for-Summary-Judgment-in-California
4 Cross-Complainant, _________________________ (“Cross-Complainant”), herein submits
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its Opposition to Plaintiffs/Cross-Defendants Motion for Summary Judgment.
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The Opposition shall be based on this Opposition, the attached Memorandum of Points and
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Authorities, the Declaration of ________________________and Exhibits attached thereto, and the
9 Separate Statement of Undisputed Material Facts, concurrently filed and served, on the complete files
10 and records of this action, and on such other oral and/or documentary evidence as may be presented
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at the hearing on the Motion.
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Dated________________ ______________________________________________
13 ANY ATTORNEY
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OPPOSITION TO MOTION FOR SUMMARY JUDGMENT

3. 1
MEMORANDUM OF POINTS AND AUTHORITIES
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3 I.
4 STATEMENT OF FACTS
5 This case arises out of ________________________________________________.
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Put down a brief description of the case, such as breach of contract action, with cross-
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complaint, etc.
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Plaintiffs complaint alleges that________________________________________. Cross-
10 complainant denies all of the allegations of Plaintiffs’ complaint.
11 Cross-complainant filed and served a Cross-Complaint for Breach of Contract, Fraud and
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Declaratory Relief against ______________________________________.
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Cross-Defendants then filed their Motion for Summary Judgment contending that because of
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the deemed admitted requests for admission against Cross-complainant that Cross-complainant’s
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16 Cross-Complaint has no merit.
17 Cross-complainant opposes Cross-Defendants Motion on the grounds that there are triable
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issues of material fact in that ______________________________________.
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Thus there are triable issues of material fact as to who breached the contract, whether Cross-
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Defendants committed fraud against Cross-complainant, and as to whether Cross-complainant is
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22 entitled to declaratory relief. Cross-complainant thus contends that the Court should deny Cross-
23 Defendants Motion and allow all of the claims in this case to be heard on their merits, as the law
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favors.
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Cross-complainant contends that it can show credible evidence of triable issues of material
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fact exist for all three causes of action of the Cross-Complaint.
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OPPOSITION TO MOTION FOR SUMMARY JUDGMENT

4. 1
MEMORANDUM OF POINTS AND AUTHORITIES
2
3 I.
4 STATEMENT OF FACTS
5 This case arises out of ________________________________________________.
6
Put down a brief description of the case, such as breach of contract action, with cross-
7
complaint, etc.
8
9
Plaintiffs complaint alleges that________________________________________. Cross-
10 complainant denies all of the allegations of Plaintiffs’ complaint.
11 Cross-complainant filed and served a Cross-Complaint for Breach of Contract, Fraud and
12
Declaratory Relief against ______________________________________.
13
Cross-Defendants then filed their Motion for Summary Judgment contending that because of
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the deemed admitted requests for admission against Cross-complainant that Cross-complainant’s
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16 Cross-Complaint has no merit.
17 Cross-complainant opposes Cross-Defendants Motion on the grounds that there are triable
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issues of material fact in that ______________________________________.
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Thus there are triable issues of material fact as to who breached the contract, whether Cross-
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Defendants committed fraud against Cross-complainant, and as to whether Cross-complainant is
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22 entitled to declaratory relief. Cross-complainant thus contends that the Court should deny Cross-
23 Defendants Motion and allow all of the claims in this case to be heard on their merits, as the law
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favors.
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Cross-complainant contends that it can show credible evidence of triable issues of material
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fact exist for all three causes of action of the Cross-Complaint.
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OPPOSITION TO MOTION FOR SUMMARY JUDGMENT

5. 1
MEMORANDUM OF POINTS AND AUTHORITIES
2
3 I.
4 STATEMENT OF FACTS
5 This case arises out of ________________________________________________.
6
Put down a brief description of the case, such as breach of contract action, with cross-
7
complaint, etc.
8
9
Plaintiffs complaint alleges that________________________________________. Cross-
10 complainant denies all of the allegations of Plaintiffs’ complaint.
11 Cross-complainant filed and served a Cross-Complaint for Breach of Contract, Fraud and
12
Declaratory Relief against ______________________________________.
13
Cross-Defendants then filed their Motion for Summary Judgment contending that because of
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the deemed admitted requests for admission against Cross-complainant that Cross-complainant’s
15
16 Cross-Complaint has no merit.
17 Cross-complainant opposes Cross-Defendants Motion on the grounds that there are triable
18
issues of material fact in that ______________________________________.
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Thus there are triable issues of material fact as to who breached the contract, whether Cross-
20
Defendants committed fraud against Cross-complainant, and as to whether Cross-complainant is
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22 entitled to declaratory relief. Cross-complainant thus contends that the Court should deny Cross-
23 Defendants Motion and allow all of the claims in this case to be heard on their merits, as the law
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favors.
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Cross-complainant contends that it can show credible evidence of triable issues of material
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fact exist for all three causes of action of the Cross-Complaint.
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OPPOSITION TO MOTION FOR SUMMARY JUDGMENT

6. 1
MEMORANDUM OF POINTS AND AUTHORITIES
2
3 I.
4 STATEMENT OF FACTS
5 This case arises out of ________________________________________________.
6
Put down a brief description of the case, such as breach of contract action, with cross-
7
complaint, etc.
8
9
Plaintiffs complaint alleges that________________________________________. Cross-
10 complainant denies all of the allegations of Plaintiffs’ complaint.
11 Cross-complainant filed and served a Cross-Complaint for Breach of Contract, Fraud and
12
Declaratory Relief against ______________________________________.
13
Cross-Defendants then filed their Motion for Summary Judgment contending that because of
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the deemed admitted requests for admission against Cross-complainant that Cross-complainant’s
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16 Cross-Complaint has no merit.
17 Cross-complainant opposes Cross-Defendants Motion on the grounds that there are triable
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issues of material fact in that ______________________________________.
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Thus there are triable issues of material fact as to who breached the contract, whether Cross-
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Defendants committed fraud against Cross-complainant, and as to whether Cross-complainant is
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22 entitled to declaratory relief. Cross-complainant thus contends that the Court should deny Cross-
23 Defendants Motion and allow all of the claims in this case to be heard on their merits, as the law
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favors.
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Cross-complainant contends that it can show credible evidence of triable issues of material
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fact exist for all three causes of action of the Cross-Complaint.
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OPPOSITION TO MOTION FOR SUMMARY JUDGMENT