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, )
ATTENDANCE AT DEPOSITION AND
)
13 PRODUCTION OF DOCUMENTS, AND FOR
vs. )
MONETARY SANCTIONS IN THE AMOUNT OF
)
14 $_________, MEMORANDUM OF POINTS AND
Any Defendant, )
AUTHORITIES, DECLARATION OF __________,
)
EXHIBITS
15 Defendant. )
) DATE:
16 ) TIME:
) DEPT:
17 )
)
18

19 TO: _____________________________ AND THEIR ATTORNEY OF

20
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

24 __________________________, ___________________________will and hereby do move this

25 Court:
26
1. For an order compelling ___________________________ to appear and testify at
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NOTICE OF MOTION AND MOTION TO COMPEL-DEPOSITION SUBPOENA
 1 the deposition, and for production of the documents specified in the deposition subpoena for
2 attendance at deposition and for production of business records duly served upon them; and
3
2. For an order of sanctions as against ______________________________,
4
in the amount of $____________ for their blatant failure and refusal to answer any questions at
5

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the duly noticed deposition and produce documents.

7 This motion is brought pursuant to Code of Civil Procedure 2025.450 on the grounds

8 that ___________ failed to appear for their duly noticed deposition on ____________ and did not
9
serve any valid objection on the moving party. The moving party further requests pursuant to Code
10
of Civil Procedure 2025.450(g)(1), the sum of $___________ in sanctions against
11
_____________________.
12

13 This Motion is made upon the grounds that ____________ provided proper notice of the

14 deponents deposition in a timely manner in accordance with Code of Civil Procedure 2020.510 by
15
serving a deposition subpoena for attendance at deposition and for production of business records and
16
______________ refused to appear for their duly noticed deposition.
17

18
This motion is based upon this notice, the attached memorandum of points and authorities,
19
declaration of _____________, and exhibits, and upon such oral and documentary evidence as
20
may be presented to the Court by _________________ at the time of the hearing.
21

22 Be sure to modify these paragraphs to suit your individual

23
situation. Do NOT just use the wording here unless it definitely applies
24

25 to your particular situation.

26
Dated________________ _______________________________________________
27
ANY ATTORNEY OR PARTY
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NOTICE OF MOTION AND MOTION TO COMPEL-DEPOSITION SUBPOENA
 1 To purchase the entire 16 page document visit:
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https://legaldocspro.myshopify.com/products/sample-motion-to-
4
compel-compliance-with-deposition-subpoena-in-california
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NOTICE OF MOTION AND MOTION TO COMPEL-DEPOSITION SUBPOENA