This document is a "Notice of Motion and Motion to Quash Subpoena Duces Tecum" filed by a defendant in a civil case. The defendant argues that the plaintiff's subpoena of the defendant's landlord should be quashed for two reasons: 1) the subpoena was not properly served on the defendant as required by law; and 2) the subpoena lacked the necessary affidavit showing good cause for the requested documents as required by law. The defendant believes the subpoena is an abuse of process intended to interfere with the landlord-tenant relationship rather than obtain legitimate discovery.
Sample meet and confer declaration for motion for judgment on the pleadings i...LegalDocsPro
This sample meet and confer declaration for a motion for judgment on the pleadings in California is filed pursuant to the new meet and confer requirement found in Code of Civil Procedure section 439(a). This declaration can be used to demonstrate compliance with the new meet and confer requirement before filing a motion for judgment on the pleadings in California that just became effective on January 1, 2018. The sample is 5 pages and includes brief instructions, sample wording and a proof of service by mail. 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.
Sample California motion to compel further responses to special interrogatoriesLegalDocsPro
This sample California motion to compel further responses to special interrogatories is made pursuant to Code of Civil Procedure Section 2030.300 and is used when a party has served special interrogatories but the responses received are evasive or incomplete, or the objections are without merit or are too general. The sample could easily be modified to apply to form interrogatories as well. The sample on which this preview is based is 30 pages and includes a memorandum of points and authorities with citations to case law and statutory authority, a separate statement as required by Rule of Court 3.1345, a sample declaration and a proof of service by mail.
This sample declaration for California can be modified for use in any case in California. The author is a freelance paralegal who has worked in California and Federal litigation since 1995 and has used this sample for many years.
Opposition to a California summary judgment motionLegalDocsPro
This sample opposition to a motion for summary judgment in California was created by a freelance paralegal who has worked in California and Federal litigation since 1995 and has used this sample for many years.
Sample California complaint for quiet titleLegalDocsPro
This sample California complaint for quiet title is verified and also includes causes of action for partition and accounting, and quiet title for California is used when a party wishes to have the Court partition certain real property, and also to quiet title to certain real property as well as obtain an accounting from the defendant. This is a preview of the sample complaint sold by LegalDocsPro.
Sample ex parte application for osc for civil contempt in CaliforniaLegalDocsPro
This sample ex parte application for Order to Show Cause for Contempt in California is filed pursuant to Code of Civil Procedure section 1209, et seq., on the grounds that a party has willfully disobeyed an order of the Court, or has otherwise committed indirect contempt. The sample ex parte application also requests the reasonable attorney’s fees and costs incurred with commencing the contempt proceeding pursuant to Code of Civil Procedure section 1218(a). 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, sample declaration regarding ex parte notice, proposed order to show cause, and proposed order re: contempt. 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 of success is provided.
Sample California motion for change of venue LegalDocsPro
This sample motion for change of venue for California is used when a defendant wants the Court to transfer the venue to their county of residence. The sample contains a memorandum of points and authorities with citations to case law and statutory authority. This is a preview of the sample motion sold by LegalDocsPro.
Sample Notice of Errata for California LegalDocsPro
This sample notice of errata for California is used to correct minor errors or omissions in declarations, motions, or other pleadings such as the late submission of a missing page or a replacement page made necessary by a glitch in photocopying. The sample includes brief instructions and a proof of service. The author is a virtual litigation paralegal that has worked in California and Federal litigation since 1995 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.
Sample meet and confer declaration for motion for judgment on the pleadings i...LegalDocsPro
This sample meet and confer declaration for a motion for judgment on the pleadings in California is filed pursuant to the new meet and confer requirement found in Code of Civil Procedure section 439(a). This declaration can be used to demonstrate compliance with the new meet and confer requirement before filing a motion for judgment on the pleadings in California that just became effective on January 1, 2018. The sample is 5 pages and includes brief instructions, sample wording and a proof of service by mail. 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.
Sample California motion to compel further responses to special interrogatoriesLegalDocsPro
This sample California motion to compel further responses to special interrogatories is made pursuant to Code of Civil Procedure Section 2030.300 and is used when a party has served special interrogatories but the responses received are evasive or incomplete, or the objections are without merit or are too general. The sample could easily be modified to apply to form interrogatories as well. The sample on which this preview is based is 30 pages and includes a memorandum of points and authorities with citations to case law and statutory authority, a separate statement as required by Rule of Court 3.1345, a sample declaration and a proof of service by mail.
This sample declaration for California can be modified for use in any case in California. The author is a freelance paralegal who has worked in California and Federal litigation since 1995 and has used this sample for many years.
Opposition to a California summary judgment motionLegalDocsPro
This sample opposition to a motion for summary judgment in California was created by a freelance paralegal who has worked in California and Federal litigation since 1995 and has used this sample for many years.
Sample California complaint for quiet titleLegalDocsPro
This sample California complaint for quiet title is verified and also includes causes of action for partition and accounting, and quiet title for California is used when a party wishes to have the Court partition certain real property, and also to quiet title to certain real property as well as obtain an accounting from the defendant. This is a preview of the sample complaint sold by LegalDocsPro.
Sample ex parte application for osc for civil contempt in CaliforniaLegalDocsPro
This sample ex parte application for Order to Show Cause for Contempt in California is filed pursuant to Code of Civil Procedure section 1209, et seq., on the grounds that a party has willfully disobeyed an order of the Court, or has otherwise committed indirect contempt. The sample ex parte application also requests the reasonable attorney’s fees and costs incurred with commencing the contempt proceeding pursuant to Code of Civil Procedure section 1218(a). 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, sample declaration regarding ex parte notice, proposed order to show cause, and proposed order re: contempt. 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 of success is provided.
Sample California motion for change of venue LegalDocsPro
This sample motion for change of venue for California is used when a defendant wants the Court to transfer the venue to their county of residence. The sample contains a memorandum of points and authorities with citations to case law and statutory authority. This is a preview of the sample motion sold by LegalDocsPro.
Sample Notice of Errata for California LegalDocsPro
This sample notice of errata for California is used to correct minor errors or omissions in declarations, motions, or other pleadings such as the late submission of a missing page or a replacement page made necessary by a glitch in photocopying. The sample includes brief instructions and a proof of service. The author is a virtual litigation paralegal that has worked in California and Federal litigation since 1995 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.
Sample California complaint to vacate judgmentLegalDocsPro
This sample California complaint to set aside and vacate a judgment is a collateral attack on a judgment also known as an independent action in equity to vacate a judgment. The sample on which this preview is based is 7 pages and contains brief instructions and two causes of action (1) to set aside and vacate the judgment on the grounds of lack of personal jurisdiction due to defective and invalid service of process, and (2) to set aside and vacate the judgment on the grounds that it was procured through extrinsic fraud or mistake.
Sample verified complaint for financial elder abuse in CaliforniaLegalDocsPro
This sample verified complaint for financial elder abuse in California contains a cause of action for financial elder abuse under Welfare and Institutions Code section 15610.30 as well as causes of action for fraud, quiet title, cancellation of written instrument and constructive trust. The sample complaint on which this preview is based requests attorney's fees and costs as well as punitive and exemplary damages under Welfare and Institutions Code section 15657.5, is 13 pages and includes brief instructions and a sample verification.The author is a freelance paralegal that has worked in California and Federal litigation since 1995 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.
Sample request for entry of default under rule 55(a) in United States Distric...LegalDocsPro
This sample request for entry of default under Rule 55(a) in United States District Court is filed pursuant to Rule 55(a) of the Federal Rules of Civil Procedure to request that the clerk enter the default of a defendant or defendants that have been properly served and have failed to plead or otherwise respond within the time limit allowed under Rule 12 of the Federal Rules of Civil Procedure. The sample is 6 pages and includes brief instructions, a sample declaration 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.
Sample motion for leave to amend answer in CaliforniaLegalDocsPro
This sample motion for leave to amend an Answer in California is filed pursuant to Code of Civil Procedure sections 473(a) and 576 on the grounds that allowing an amended Answer to be filed would further the interests of justice. The sample on which this preview is based is 12 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service by mail.
Sample motion for consolidation of cases in CaliforniaLegalDocsPro
This sample motion for consolidation of multiple cases in California is filed pursuant to Code of Civil Procedure section 1048(a) to request consolidation of two or more cases. The motion is used by a party who is requesting that a Court consolidate two or more cases on the grounds that consolidation of the cases is warranted in that all of the cases arise out of the same set of operative facts and contain common issues and further that consolidation of all of the cases will avoid unnecessary duplication of evidence and procedures in all of the actions; avoid the risk of inconsistent adjudications and avoid many of the same witnesses testifying on common issues in all actions as well as promote judicial economy and convenience. The sample on which this preview is based can be easily modified for use in cases where complete consolidation is requested or where consolidation is requested only for purposes of trial and is 19 pages including brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration, proof of service by mail and proposed order. The author is an entrepreneur and freelance paralegal who has worked in California and Federal litigation since 1995 and has created over 250 sample legal documents for sale.
Sample motion for Family Code section 271 sanctions in CaliforniaLegalDocsPro
This sample motion for Family Code section 271 sanctions in California may be filed in any dissolution (divorce), legal separation or nullity action in California and is designed to be used in conjunction with a Request for Order Judicial Council Form FL-300. The motion is used to request an award of damages and sanctions under Family Code section 271 and 1100, et seq. on the grounds that the conduct of the other party and/or their attorney frustrated any expeditious settlement of the case and caused the moving party to have to incur additional costs and attorney’s fees as a result of the obstreperous conduct. The sample document on which this preview is based is 15 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority and sample declaration.
Sample opposition to demurrer for californiaLegalDocsPro
This sample opposition to demurrer for California was created by a freelance paralegal who has worked in California and Federal litigation since 1995 and has used this sample for many years.
Sample meet and confer declaration for motion to strike in California LegalDocsPro
This sample meet and confer declaration for a motion to strike in California is filed under Code of Civil Procedure § 435.5(a) to demonstrate compliance with the new meet and confer requirements before a motion to strike can be filed that became effective on January 1, 2018. The sample is 5 pages and includes brief instructions, sample wording and a proof of service by mail. 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.
Sample ex parte application for continuance of trial date for California evic...LegalDocsPro
This sample ex-parte application for a continuance of trial date in an unlawful detainer (eviction) in California is filed under the provisions of California Rule of Court 3.1332 and Code of Civil Procedure section 1170.5 and contends that a continuance is necessary due to illness of a party or witness or other grounds specified in California Rule of Court 3.1332. The sample on which this preview is based is 15 pages and include brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and sample declaration regarding notice of ex-parte hearing and proposed order.
Sample opposition to request for domestic violence restraining order in Calif...LegalDocsPro
This sample opposition to request for domestic violence restraining order in California is used to oppose a request for a domestic violence restraining order in California on the grounds that (1) the Petitioner has failed to meet their burden of showing reasonable proof of a past act or acts of abuse as required by California law and (2) the conduct of the opposing party does not constitute domestic violence and the law in California clearly states that the purpose of a domestic violence restraining order namely Family Code § 6300 is to prevent a recurrence of domestic violence and to ensure a period of separation of the parties involved. The sample on which this preview is based is 13 pages and contains brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration 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. Note that the author is NOT an attorney and no guarantee or warranty is provided.
Sample motion to vacate California divorce judgment for fraudLegalDocsPro
This sample motion to vacate a dissolution (divorce) judgment in California on the grounds of duress is used pursuant to California Family Code section 2122(c). This sample can also be used to vacate a legal separation or nullity judgment in California as well. The sample on which this preview is based is 10 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority and a sample declaration.
Sample California reply to opposition to motionLegalDocsPro
This document is a sample California reply to an opposition to a motion. This sample is used to reply to an opposition filed to a motion. Note that the author is NOT an attorney and no guarantee or warranty is provided.
Sample notice of unavailability of counsel for CaliforniaLegalDocsPro
This sample notice of unavailability of counsel for California is used to notify opposing counsel or the opposing party of the unavailability of counsel during a specified period of time for any court hearings or depositions, etc. This notice is served pursuant to the California Court of Appeal decision in Tenderloin Housing Clinic, Inc. v. Sparks, 8 Cal. App. 4th 299, 307 (1992). The sample includes brief instructions and a proof of service by mail. The author is a freelance paralegal who has worked in California and Federal litigation since 1995. Note that the author is NOT an attorney and no guarantee or warranty is provided.
Sample motion for OSC for contempt for violations of the Bankruptcy Discharge...LegalDocsPro
This sample motion for OSC for contempt for violations of the Bankruptcy Discharge Injunction is filed pursuant to the Bankruptcy Court's contempt authority under § 105(a) of the United States Bankruptcy Code. The motion is designed to be filed by a Debtor against a Creditor that has willfully violated the Bankruptcy Discharge Injunction such as filing a State Court lawsuit after receiving notice that the Debtor has been granted a discharge. The motion requests that the Creditor be held in contempt and requests actual damages, emotional distress damages, punitive damages and attorney's fees and costs. The sample motion on which this preview is based is 30 pages and includes a memorandum of points and authorities with citations to Case law from the Ninth Circuit Court of Appeals, Bankruptcy Appellate Panel and the United States Bankruptcy Code , sample declarations for the Debtor and the Attorney for the Debtor, sample Request for Judicial Notice and sample Proposed Order Re: Contempt The sample motion is in Microsoft Word format and can be easily modified for most situations. 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.
Sample motion for sanctions under Code of Civil Procedure section 128.5 in ca...LegalDocsPro
This sample motion for sanctions under Code of Civil Procedure section 128.5 in California is filed on the grounds that another party has engaged in bad faith actions or or tactics that are frivolous or solely intended to cause unnecessary delay such as filing numerous frivolous motions or complaints. The sample is 13 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service. The author is an entrepreneur and freelance paralegal that has worked in California and Federal litigation since 1995 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.
Sample California demurrer to complaint for breach of contractLegalDocsPro
This sample California demurrer to a complaint for breach of contract and common counts is made on the grounds that the causes of action fail to state sufficient facts as it cannot be ascertained whether any contract was written, oral or implied by conduct, no contract is attached and on other grounds as well. This is a preview of the 12 page sample sold on scribd.com by LegalDocsPro which includes a memorandum of points and authorities with citations to case law and statutory authority and a proof of service by mail.
Sample California motion to strike answer LegalDocsPro
This sample motion to strike an answer to a complaint for California is made pursuant to Sections 435-437 of the Code of Civil Procedure. The sample requests that the entire answer be stricken as it is not verified, or in the alternative that all of the affirmative defenses contained in the answer should be stricken as they contain only immaterial allegations. The sample contains brief instructions, a memorandum of points and authorities and a proof of service by mail.
Sample notice of ruling for CaliforniaLegalDocsPro
This sample notice of ruling for California can be modified for use in any litigation case in California. The author is a freelance paralegal who has worked in California and Federal litigation since 1995 and has used this sample for many years.
Sample motion to vacate stipulation in California divorceLegalDocsPro
This sample motion to vacate stipulation for California dissolution (divorce) case is filed pursuant to Code of Civil Procedure section 473 and Family Code section 210 and is used when a party wishes to have the court vacate a settlement or stipulation entered into on the grounds of mistake, inadvertence, excusable neglect, fraud, mistake of law or fact, where the facts stipulated have changed or there has been a change in the underlying that could not have been anticipated, or where special circumstances exist rendering it unjust to enforce the stipulation. The sample on which this preview is based is 11 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service by mail.
Sample California complaint to vacate judgmentLegalDocsPro
This sample California complaint to set aside and vacate a judgment is a collateral attack on a judgment also known as an independent action in equity to vacate a judgment. The sample on which this preview is based is 7 pages and contains brief instructions and two causes of action (1) to set aside and vacate the judgment on the grounds of lack of personal jurisdiction due to defective and invalid service of process, and (2) to set aside and vacate the judgment on the grounds that it was procured through extrinsic fraud or mistake.
Sample verified complaint for financial elder abuse in CaliforniaLegalDocsPro
This sample verified complaint for financial elder abuse in California contains a cause of action for financial elder abuse under Welfare and Institutions Code section 15610.30 as well as causes of action for fraud, quiet title, cancellation of written instrument and constructive trust. The sample complaint on which this preview is based requests attorney's fees and costs as well as punitive and exemplary damages under Welfare and Institutions Code section 15657.5, is 13 pages and includes brief instructions and a sample verification.The author is a freelance paralegal that has worked in California and Federal litigation since 1995 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.
Sample request for entry of default under rule 55(a) in United States Distric...LegalDocsPro
This sample request for entry of default under Rule 55(a) in United States District Court is filed pursuant to Rule 55(a) of the Federal Rules of Civil Procedure to request that the clerk enter the default of a defendant or defendants that have been properly served and have failed to plead or otherwise respond within the time limit allowed under Rule 12 of the Federal Rules of Civil Procedure. The sample is 6 pages and includes brief instructions, a sample declaration 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.
Sample motion for leave to amend answer in CaliforniaLegalDocsPro
This sample motion for leave to amend an Answer in California is filed pursuant to Code of Civil Procedure sections 473(a) and 576 on the grounds that allowing an amended Answer to be filed would further the interests of justice. The sample on which this preview is based is 12 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service by mail.
Sample motion for consolidation of cases in CaliforniaLegalDocsPro
This sample motion for consolidation of multiple cases in California is filed pursuant to Code of Civil Procedure section 1048(a) to request consolidation of two or more cases. The motion is used by a party who is requesting that a Court consolidate two or more cases on the grounds that consolidation of the cases is warranted in that all of the cases arise out of the same set of operative facts and contain common issues and further that consolidation of all of the cases will avoid unnecessary duplication of evidence and procedures in all of the actions; avoid the risk of inconsistent adjudications and avoid many of the same witnesses testifying on common issues in all actions as well as promote judicial economy and convenience. The sample on which this preview is based can be easily modified for use in cases where complete consolidation is requested or where consolidation is requested only for purposes of trial and is 19 pages including brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration, proof of service by mail and proposed order. The author is an entrepreneur and freelance paralegal who has worked in California and Federal litigation since 1995 and has created over 250 sample legal documents for sale.
Sample motion for Family Code section 271 sanctions in CaliforniaLegalDocsPro
This sample motion for Family Code section 271 sanctions in California may be filed in any dissolution (divorce), legal separation or nullity action in California and is designed to be used in conjunction with a Request for Order Judicial Council Form FL-300. The motion is used to request an award of damages and sanctions under Family Code section 271 and 1100, et seq. on the grounds that the conduct of the other party and/or their attorney frustrated any expeditious settlement of the case and caused the moving party to have to incur additional costs and attorney’s fees as a result of the obstreperous conduct. The sample document on which this preview is based is 15 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority and sample declaration.
Sample opposition to demurrer for californiaLegalDocsPro
This sample opposition to demurrer for California was created by a freelance paralegal who has worked in California and Federal litigation since 1995 and has used this sample for many years.
Sample meet and confer declaration for motion to strike in California LegalDocsPro
This sample meet and confer declaration for a motion to strike in California is filed under Code of Civil Procedure § 435.5(a) to demonstrate compliance with the new meet and confer requirements before a motion to strike can be filed that became effective on January 1, 2018. The sample is 5 pages and includes brief instructions, sample wording and a proof of service by mail. 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.
Sample ex parte application for continuance of trial date for California evic...LegalDocsPro
This sample ex-parte application for a continuance of trial date in an unlawful detainer (eviction) in California is filed under the provisions of California Rule of Court 3.1332 and Code of Civil Procedure section 1170.5 and contends that a continuance is necessary due to illness of a party or witness or other grounds specified in California Rule of Court 3.1332. The sample on which this preview is based is 15 pages and include brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and sample declaration regarding notice of ex-parte hearing and proposed order.
Sample opposition to request for domestic violence restraining order in Calif...LegalDocsPro
This sample opposition to request for domestic violence restraining order in California is used to oppose a request for a domestic violence restraining order in California on the grounds that (1) the Petitioner has failed to meet their burden of showing reasonable proof of a past act or acts of abuse as required by California law and (2) the conduct of the opposing party does not constitute domestic violence and the law in California clearly states that the purpose of a domestic violence restraining order namely Family Code § 6300 is to prevent a recurrence of domestic violence and to ensure a period of separation of the parties involved. The sample on which this preview is based is 13 pages and contains brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration 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. Note that the author is NOT an attorney and no guarantee or warranty is provided.
Sample motion to vacate California divorce judgment for fraudLegalDocsPro
This sample motion to vacate a dissolution (divorce) judgment in California on the grounds of duress is used pursuant to California Family Code section 2122(c). This sample can also be used to vacate a legal separation or nullity judgment in California as well. The sample on which this preview is based is 10 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority and a sample declaration.
Sample California reply to opposition to motionLegalDocsPro
This document is a sample California reply to an opposition to a motion. This sample is used to reply to an opposition filed to a motion. Note that the author is NOT an attorney and no guarantee or warranty is provided.
Sample notice of unavailability of counsel for CaliforniaLegalDocsPro
This sample notice of unavailability of counsel for California is used to notify opposing counsel or the opposing party of the unavailability of counsel during a specified period of time for any court hearings or depositions, etc. This notice is served pursuant to the California Court of Appeal decision in Tenderloin Housing Clinic, Inc. v. Sparks, 8 Cal. App. 4th 299, 307 (1992). The sample includes brief instructions and a proof of service by mail. The author is a freelance paralegal who has worked in California and Federal litigation since 1995. Note that the author is NOT an attorney and no guarantee or warranty is provided.
Sample motion for OSC for contempt for violations of the Bankruptcy Discharge...LegalDocsPro
This sample motion for OSC for contempt for violations of the Bankruptcy Discharge Injunction is filed pursuant to the Bankruptcy Court's contempt authority under § 105(a) of the United States Bankruptcy Code. The motion is designed to be filed by a Debtor against a Creditor that has willfully violated the Bankruptcy Discharge Injunction such as filing a State Court lawsuit after receiving notice that the Debtor has been granted a discharge. The motion requests that the Creditor be held in contempt and requests actual damages, emotional distress damages, punitive damages and attorney's fees and costs. The sample motion on which this preview is based is 30 pages and includes a memorandum of points and authorities with citations to Case law from the Ninth Circuit Court of Appeals, Bankruptcy Appellate Panel and the United States Bankruptcy Code , sample declarations for the Debtor and the Attorney for the Debtor, sample Request for Judicial Notice and sample Proposed Order Re: Contempt The sample motion is in Microsoft Word format and can be easily modified for most situations. 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.
Sample motion for sanctions under Code of Civil Procedure section 128.5 in ca...LegalDocsPro
This sample motion for sanctions under Code of Civil Procedure section 128.5 in California is filed on the grounds that another party has engaged in bad faith actions or or tactics that are frivolous or solely intended to cause unnecessary delay such as filing numerous frivolous motions or complaints. The sample is 13 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service. The author is an entrepreneur and freelance paralegal that has worked in California and Federal litigation since 1995 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.
Sample California demurrer to complaint for breach of contractLegalDocsPro
This sample California demurrer to a complaint for breach of contract and common counts is made on the grounds that the causes of action fail to state sufficient facts as it cannot be ascertained whether any contract was written, oral or implied by conduct, no contract is attached and on other grounds as well. This is a preview of the 12 page sample sold on scribd.com by LegalDocsPro which includes a memorandum of points and authorities with citations to case law and statutory authority and a proof of service by mail.
Sample California motion to strike answer LegalDocsPro
This sample motion to strike an answer to a complaint for California is made pursuant to Sections 435-437 of the Code of Civil Procedure. The sample requests that the entire answer be stricken as it is not verified, or in the alternative that all of the affirmative defenses contained in the answer should be stricken as they contain only immaterial allegations. The sample contains brief instructions, a memorandum of points and authorities and a proof of service by mail.
Sample notice of ruling for CaliforniaLegalDocsPro
This sample notice of ruling for California can be modified for use in any litigation case in California. The author is a freelance paralegal who has worked in California and Federal litigation since 1995 and has used this sample for many years.
Sample motion to vacate stipulation in California divorceLegalDocsPro
This sample motion to vacate stipulation for California dissolution (divorce) case is filed pursuant to Code of Civil Procedure section 473 and Family Code section 210 and is used when a party wishes to have the court vacate a settlement or stipulation entered into on the grounds of mistake, inadvertence, excusable neglect, fraud, mistake of law or fact, where the facts stipulated have changed or there has been a change in the underlying that could not have been anticipated, or where special circumstances exist rendering it unjust to enforce the stipulation. The sample on which this preview is based is 11 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service by mail.
Sample California motion to vacate order of dismissalLegalDocsPro
This sample motion to vacate order of dismissal in California is made under Code of Civil Procedure section 473 on the grounds that the order of dismissal was taken against the moving party through their mistake and inadvertence. The sample on which this preview is based is 13 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declarations and a proof of service by mail.
The "Audio-visual management" module is focused to adults learners interested in exploring the possibilities of managing multimedia tools of hight level. This module brings the opportunity to work together the skills learned in the previous 4 modules with the aim to create an audiovisual project.
This module is part of a set of materials designed and developed in the project Telecentre Multimedia Academy (Lifelong learning - Grundtvig (2012-2014)) project.
The Telecentre Multimedia Academy is a project where Fundación Esplai worked with a consortium of 8 partners from Croatia, Latvia, Lithuania, Romania, Serbia and Hungary, whose coordinator is Telecentre Europe.
You can learn more about the Telecentre Multimedia Academy project in:
http://fundacionesplai.org/e-inclusion-internacional/tma/
Finding audio visual resources in Goldsmiths Librarykevinwilsongold
This presentation covers why and how students use Audio-visual information, what collections Goldsmiths has and subscribes to, as well as information about various public archives of AV material. There's also information about citing this material.
Sample motion to strike punitive damages in californiaLegalDocsPro
This sample motion to strike punitive damages allegations in California is used when the complaint includes only boilerplate and conclusory allegations in support of a request for punitive damages and/or improperly states the amount of punitive damages that are sought. The sample on which this preview is based is 11 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority and proof of service by mail. The author is a freelance paralegal that has worked in California and Federal litigation since 1995 and has created over 300 sample legal documents for sale.
This a sample offer to compromise or also known as a 998 offer for California is pursuant to Section 998 of the Code of Civil Procedure. This sample is used when a defendant wants to make an offer to compromise to the plaintiff. It can be adapted for use by a plaintiff who wishes to make an offer to compromise to a defendant.
The author is a freelance paralegal who has worked in California and Federal litigation since 1995 and has used this sample for many years. Note that the author is NOT an attorney and no guarantee or warranty is provided.
Sample motion to vacate judgment under rule 60(b)(1) in United States Bankrup...LegalDocsPro
This sample motion to vacate a judgment or order in United States Bankruptcy Court is filed using the grounds of on the grounds of mistake, inadvertence, surprise, or excusable neglect under Federal Rule of Bankruptcy Procedure 9024 and Federal Rule of Civil Procedure 60(b)(1) . The sample on which this preview is based is 11 pages and contains brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service by mail. The author is an entrepreneur and freelance paralegal that has worked in California and Federal litigation since 1995 and has created over 300 sample legal documents for sale.
Sample California motion to vacate default judgment under Code of Civl Proced...LegalDocsPro
This sample motion to vacate a default judgment in California on the grounds of lack of actual notice in time to defend the action is made pursuant to Section 473.5 of the Code of Civil Procedure. The sample contains a memorandum of points and authorities with citations to case law and statutory authority. This is a preview of the sample motion sold by LegalDocsPro.
Sample opposition to motion to vacate in California with an attorney affidavi...LegalDocsPro
This sample opposition to California motion to vacate judgment with an attorney affidavit of fault is used to oppose a motion made under the mandatory attorney affidavit of fault provisions of Code of Civil Procedure section 473(b) on several grounds including that the motion is untimely, does not include the required attorney affidavit of fault, the attorney is covering up for the client and other grounds. The sample on which this preview is based is 12 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority and a sample declaration.
Sample motion to correct clerical error in California judgmentLegalDocsPro
This sample motion to correct a clerical error in a California judgment by amending the judgment is filed pursuant to the provisions of Code of Civil Procedure section 473(d). The motion requests that the judgment be amended nunc pro tunc on the grounds that their clerical error has caused the judgment that was actually entered to not accurately reflect the outcome indicated when the judgment was originally declared. The sample on which this preview is based is 14 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority; sample declaration, proposed order and proof of service by mail.
Sample motion to vacate sister state judgment in CaliforniaLegalDocsPro
This sample motion to vacate a sister state judgment in California is filed under the provisions of Code of Civil Procedure section 1710.40 on the grounds that the judgment is void because service was defective or was not made at all. The sample is 11 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service by mail. The author is an entrepreneur and freelance paralegal who has worked in California and Federal litigation since 1995 and has created over 255 sample legal documents for California and Federal litigation.
Sample California opposition to anti-SLAPP motion LegalDocsPro
This sample opposition to a special motion to strike or anti-SLAPP motion in California is designed to oppose a special motion to strike on the grounds (1) that it is untimely in that it was filed more than 60 days after service of the summons and complaint in violation of Code of Civil Procedure section 425.16(f); (2) defendant has failed to meet their burden of making a threshold showing that the challenged causes of action are ones arising from protected activity and (3) the motion should be denied as Plaintiff can show a reasonable probability of prevailing on their causes of action. The sample on which this preview is based is 13 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service.
Sample ex parte application for TRO and preliminary injunction in United Stat...LegalDocsPro
This sample ex parte application for temporary restraining order in United States District Court also requests the issuance of a preliminary injunction pending the trial pursuant to Federal Rule of Civil Procedure 65(a) and (b) on the grounds that the plaintiff has suffered and will continue to suffer, substantial irreparable harm if injunctive relief is not granted. The sample on which this preview is based is 16 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proposed order. 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.
Sample petition to vacate arbitration award in CaliforniaLegalDocsPro
This sample petition to vacate an arbitration award in California pursuant to Code of Civil Procedure section 1286.2 can be used on one or more of several grounds including (1) The award was procured by corruption, fraud or other undue means; (2) There was corruption in any of the arbitrators; (3) The rights of the party were substantially prejudiced by misconduct of a neutral arbitrator; (4) The arbitrators exceeded their powers and the award cannot be corrected without affecting the merits of the decision upon the controversy submitted; (5) The rights of the party were substantially prejudiced by the refusal of the arbitrators to postpone the hearing upon sufficient cause being shown therefor or by the refusal of the arbitrators to hear evidence material to the controversy or by other conduct of the arbitrators contrary to the provisions of this title, and (6) An arbitrator making the award either: (A) failed to disclose within the time required for disclosure a ground for disqualification of which the arbitrator was then aware; or (B) was subject to disqualification upon grounds specified in Section 1281.91 but failed upon receipt of timely demand to disqualify himself or herself as required by that provision. The sample on which this preview is based is 14 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority and sample declaration. The author is an entrepreneur and freelance paralegal that has worked in California and Federal litigation since 1995 and has created over 300 sample documents for sale.
Sample motion to vacate judgment under rule 60(b)(2) in United States Distric...LegalDocsPro
This sample motion to vacate a judgment under Rule 60(b)(2) on the grounds of newly discovered evidence in United States District Court is used when a party has newly discovered evidence that, with reasonable diligence, could not have been discovered in time to move for a new trial under Rule 59(b). The sample on which this preview based is 10 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, a sample declaration and proof of service by mail.
Sample California motion to compel responses to requests for production of do...LegalDocsPro
This sample California motion to compel responses to requests for production of documents is made pursuant to Code of Civil Procedure Section 2031.300(b) and is used when a party has served requests for production of documents special interrogatories but has received NO responses or documents. The sample could easily be modified to apply to form interrogatories as well. The sample on which this preview is based is 9 pages and includes a memorandum of points and authorities with citations to case law and statutory authority, a sample declaration and a proof of service by mail.
Sample opposition to motion for reconsideration in CaliforniaLegalDocsPro
This sample motion for reconsideration in California is made on the grounds that the motion does not comply with Code of Civil Procedure section 1008(a) as it is not timely and no new or different facts, circumstances or law are provided that would support granting reconsideration. The sample on which this preview is based includes brief instructions, a memorandum of points and authorities with citations to case law and statutory, sample declaration and proof of service by mail.
Sample plaintiffs opposition to motion for judgment on the pleadings in Calif...LegalDocsPro
This sample Plaintiffs opposition to a motion for judgment on the pleadings in California is filed on the grounds that (1) the complaint does state valid causes of action and (2) that Defendants demurrer is without merit. The sample opposition on which this preview is based is 9 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority 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.
Sample opposition to motion to expunge lis pendens in californiaLegalDocsPro
This sample opposition to a motion to expunge a Lis Pendens in California is made on the grounds that (1) plaintiff has met their burden of showing that the complaint or cross-complaint states a real property claim as defined in Code of Civil Procedure section 405.4 as the causes of action affect the title to, or right to possession of specific real property, (2) plaintiff has met their burden of showing the probable validity of their claim as defined in Code of Civil Procedure section 405.3 as they have shown that it is more likely than not that they will obtain a judgment against the defendant on the claim. The opposition also requests sanctions against the moving party pursuant to Code of Civil Procedure section 405.38 on the grounds that the moving party filed the motion to expunge the Lis Pendens without a showing of good cause or substantial justification. The sample on which this preview is based is 13 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service.
Sample motion for order compelling satisfaction of judgment in CaliforniaLegalDocsPro
This sample motion for an order compelling a full satisfaction of judgment in California can be filed by a judgment debtor that has fully satisfied a judgment and the judgment creditor has refused to comply with a written demand for a full satisfaction of judgment within 15 days.
The motion is filed is filed pursuant to the provisions of Code of Civil Procedure section 724.050(d). The sample motion requests an order compelling the judgment creditor to execute, acknowledge and file an acknowledgment of full satisfaction of judgment with the court and record a certified copy of the filed acknowledgment of satisfaction of judgment with the County Recorder of the County where the abstract of judgment was recorded. The sample also requests actual and statutory damages pursuant to Code of Civil Procedure section 724.050(e) and reasonable attorney's fees under Code of Civil Procedure section 724.080. The sample on which this preview is based is 15 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declarations, and proof of service. The author is a freelance paralegal that has worked in California and Federal litigation since 1995 and has created over 300 sample legal documents for sale.
Sample opposition to petition to compel arbitration in CaliforniaLegalDocsPro
This sample opposition to a petition to compel arbitration is used to oppose a request to compel arbitration on the grounds that the arbitration agreement should not be enforced due to fraud, duress, the agreement is unconscionable, one-sided or an adhesion contract, the moving party unreasonably delayed in seeking arbitration, acted in bad faith and other grounds. The sample on which this preview is based is 20 pages and includes brief instructions, a table of contents and table of authorities as well as a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service. The author of this document has worked in California and Federal litigation since 1995.
Sample motion for family code section 1101 damages and sanctionsLegalDocsPro
This sample motion for damages and sanctions in California for concealment of community property in a divorce case is designed to be used with a notice of motion or request for order and is filed under the provisions of Family Code sections 721 and 1101 on the grounds that the other party breached their fiduciary duty by intentionally concealing valuable community property. The sample also requests sanctions under Family Code sections 271 and 2100 for the failure to disclose valuable community property. The sample document on which this preview is based is 17 pages and includes brief instructions, a memorandum of points and authorities including a table of contents, table of authorities and citations to case law and statutory authority and sample declaration.
Sample California complaint for breach of contract and common countsLegalDocsPro
This sample California complaint for breach of contract also includes causes of action for common counts including open book account, account stated and goods sold and delivered. The sample on which this preview is based is 6 pages and includes brief instructions. The sample document is sold on scribd.com by LegalDocsPro.
Sample petition for final distribution for probate in CaliforniaLegalDocsPro
This sample petition for final distribution in a probate case in California is filed to request that the Court make an order of final distribution and approve the statutory compensation for the personal representative and their attorney. The sample petition on which this preview is based is 18 pages and includes brief instructions, a sample summary of account, sample exhibits to support the summary of account and a sample verification. The author is an entrepreneur and freelance paralegal that has worked in California and Federal litigation since 1995 and has created over 300 sample legal documents for sale.
Sample opposition to order to show cause for civil contempt in CaliforniaLegalDocsPro
This sample opposition to an order to show cause for civil contempt in California is made on the grounds that (1) the opposing party has not willfully violated the terms of any Court orders, (2) the party charging them with contempt has failed to meet their burden of proving their guilt beyond a reasonable doubt in that they have failed to submit competent evidence that would support a finding that they willfully violated the TRO, which is an essential element of a finding of contempt. The sample opposition also requests that the Court hold a full and fair evidentiary hearing in which they are allowed to confront and cross-examine all witnesses against them. The sample on which this preview is based is 10 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service. The author is a legal 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.
Similar to Writing Sample Goldman Motion to Quash Pleading (20)
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28 NOTICE OF MOTION AND MOTION TO QUASH SUBPOENA DUCES TECUM
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[Attorney’s Name Redacted]
[Attorney’s Business Address Redacted]
[City, State Zip Code Redacted
[Phone Redacted]
[Email Redacted]
COURT NAME [REDACTED]
JURISDICTION [REDACTED]
[PLAINTIFF’S NAME REDACTED],
Plaintiff,
vs.
[DEFENDANT’S NAME REDACTED],
DOES 1 THRU 25 INCLUSIVE
Defendant
Case No.: [REDACTED]
NOTICE OF MOTION AND
MOTION TO QUASH DEPOSITION OF
SUBPOENA DUCES TECUM, AND
MEMORANDUM OF POINTS AND
AUTHORITIES, AND DECLARATION OF
[NAME REDACTED]
DATE: [REDACTED]
TIME: [REDACTED]
DEPT: [REDACTED]
TO PLAINTIFF AND ITS COUNSEL:
NOTICE IS HEREBY GIVEN that on [DATE REDACTED] at 1:30 PM in Department 00A of
this Court [or whichever courtroom to which this matter is assigned], Defendant will and does
hereby move the Court to quash the subpoena duces tecum, on grounds of failure to effectuate
proper service of process, under California Code of Civil Procedure § 1987.1, In addition,
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28 NOTICE OF MOTION AND MOTION TO QUASH SUBPOENA DUCES TECUM
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Plaintiff’s subpoena is an abuse of discovery, because it seeks to maliciously malign Defendant
by disrupting her current landlord/tenant relationship .
This motion is based upon the following points and authorities, and Declaration of
[NAME REDACTED].
DEFENDANT DOES NOT STIPULATE TO A COMMISSIONER OR JUDGE PRO
TEM participating in any aspect of this matter [Cal. Const. Art. 6 § 21], and will submit on the
papers absent actual appearance. [CRC § 3.1304(c)].
______________________________
[DEFENDANT’S NAME REDACTED]
MEMORANDUM OF POINTS AND AUTHORITIES
Introduction
A money judgment was obtained in Plaintiff’s favor for which Plaintiff has issued a
subpoena duces tecum to Defendant’s current landlord. However, Plaintiff failure to follow
California Code of Civil Procedure to effectuate proper service of process constitutes an abuse
process, discovery and remedy.
1. Service of Subpoena Duces Tecum was not by Personal Service.
Plaintiff has subpoenaed personal records as defined in California Code of Civil
Procedure (CCP) § 1985.3(a)(1), which [must] be personally served on Defendant or served by
mail, as required by CCP § 1985.3(c)(1) which states in part:
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28 NOTICE OF MOTION AND MOTION TO QUASH SUBPOENA DUCES TECUM
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“. . . serve or cause to be served upon the witness a proof of personal service or of
service by mail attesting to compliance with subdivision (b).”
And continues,
“(b) Prior to the date called for in the subpoena duces tecum for the production of
personal records, the subpoenaing party shall serve or cause to be served on the
consumer whose records are being sought a copy of the subpoena duces tecum, of
the affidavit supporting the issuance of the subpoena, if any, and of the notice
described in subdivision (c), and proof of service as indicated in paragraph (1) of
subdivision (c).”
CCP § 1985.3(b) requires proof of service upon deponent be named in the
document. In the case at hand, the entry for proof of service upon the deponent was left
blank, indicating that there was no such service, and fails to comply with CCP § 1985(b),
even if the service on the deponent had been properly accomplished. Plaintiff has failed
to comply with the prerequisites of due process and service of process of the subpoena
duces tecum. Therefore, the entire subpoena must be quashed. CCP §§ 1985.3(g) and
1987.1.
Defendant requests this Court quash the Plaintiff’s subpoena duces tecum.
2. Service of the Subpoena Duces Tecum lacked the required affidavit.
Pursuant to CCP § 1985(b) “Where a subpoena duces tecum is served, it must be
accompanied by an affidavit showing good cause for the production of the matters
and things described in the subpoena, specifying the exact matters or things
desired to be produced, setting forth in full detail the materiality thereof to the
issues involved in the case, and stating that the witness has the desired matters or
things in his or her possession or under his or her control.”
The subject subpoena contains no such affidavit showing good cause for the
production of the matters, nor does it show things described specifying the exact matters
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28 NOTICE OF MOTION AND MOTION TO QUASH SUBPOENA DUCES TECUM
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or things desired to be produced, nor does it set forth in full detail the materiality thereof
to the issues involved in the case, nor does it set forth that the witness has the desire
matters or things in his or her possession or under his or her control.”
Plaintiff’s failure to set forth good cause was sought for vengeance. Plaintiff’s
attempt to contact Defendant’s current landlord was motivated by retaliation, packaged in
the guise of a subpoena for discovery. Plaintiff’s subpoena is an attempt to insinuate that
Defendant should be evicted or distrusted under the current landlord/tenant lease.
Plaintiff’s retaliatory motivation is based on the fact that Defendant for asserted her rights
to contact government officials and agencies in the subject action. Plaintiff’s subpoena
amounts to tortious interference with contract and an abuse of process. Without the
requisite affidavit, the Plaintiff’s subpoena duces tecum fails to comply with the
aforementioned statute and must be quashed in its entirety.
For all the foregoing reasons, Defendant requests this Court quash the Plaintiff’s
subpoena duces tecum quashed.
Respectively submitted,
____________________________
[Attorney’s Name Redacted]
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28 NOTICE OF MOTION AND MOTION TO QUASH SUBPOENA DUCES TECUM
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DECLARATION OF [DECLARANT’S NAME REDACTED]
STATE OF CALIFORNIA
COUNTY OF LOS ANGELES
I, [Declarant’s name redacted], state:
I am a Defendant in this action and make this declaration of my own personal
knowledge.
Attached hereto is the Plaintiff’s subpoena duces tecum purportedly served upon
my current landlord, [Landlord’s Name Redacted]. The proof of service which I received
is blank, and I have reason to believe that the one served upon [Landlord’s Name
Redacted] is also blank. In addition, Plaintiff failed to attach an affidavit showing good
cause for serving the subpoena on [Landlord’s Name Redacted].
Plaintiff’s service of the subpoena of my current landlord fails to state any good
cause, moreover Plaintiff failed to attach the requisite affidavit delineating good cause.
Landlord is not an income source for myself, nor does he hold any assets that could be
used to satisfy a judgment in Plaintiff’s favor. The transparent reason for serving the
subpoena on my current landlord is to tortuously interfere with my current
landlord/tenant relationship, seeking to exact unwarranted distrust between myself and
Landlord. Plaintiff’s continued harassment is motivated by vengeance for my asserting
my rights to the proper government authorities and agencies. The subpoena duces tecum
is an abuse of process, intended to harass and malign.
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I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
EXECUTED THIS ____ DAY OF __________, ______ AT [CITY NAME
REDACTED], CALIFORNIA.
_________________________________
[DEFENDANT’S NAME REDACTED]
_____________________________________________________________________________
PROOF OF SERVICE BY MAIL
STATE OF CALIFORNIA, COUNTY OF [NAME REDACTED]
I am employed in the County of [NAME REDACTED] at [ADDRESS REDACTED].
I am over the age of 18 and not a party to the within action.
On [DATE REDACTED], I served the document attached hereto on the opposing
party(s) in this action by placing a true copy thereof enclosed in a sealed envelope with postage
thereon fully prepaid in the United States mail at [CITY NAME REDACTED], California,
addressed to:
[ATTORNEY’S NAME AND ADDRESS REDACTED]
I declare under penalty of perjury under the laws of the State of California that the above
is true and correct. Executed on [DATE REDACTED] at [CITY NAME REDACTED],
California.
___________________________________
[NAME AND SIGNATURE REDACTED]