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 of _________________

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11 Any Plaintiff, ) Case No.

Plaintiff, )
12 vs. ) OPPOSITION TO COMPEL FURTHER
Any Defendants, and DOES 1-5, inclusive, ) RESPONSES TO REQUESTS FOR
13 Defendants. ) PRODUCTION OF DOCUMENTS AND FOR
) SANCTIONS; MEMORANDUM OF POINTS AND
14 ) AUTHORITIES; DECLARATION OF _________;
) EXHIBITS
15 )
) DATE:
16 ) TIME:
) DEPT:
17 )
)
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)
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OPPOSITION TO MOTION TO COMPEL FURTHER REPONSES TO REQUESTS FOR DOCUMENTS

1 Be sure to remove this notice and all other notices before using
2

3
this document.
4 NAME AND PARTY CAPACITY herein submits its Opposition to the motion to compel
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filed by NAME AND PARTY CAPACITY on the grounds that ________ the requests for
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production of documents are objectionable in that the documents requested clearly do not relate to the
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claim or defense of the party seeking discovery or of any other party to the action as required by
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9 Code of Civil Procedure § 2017.010, and on the further grounds that the requests for production of

10 document are unduly burdensome and oppressive in that LIST HERE THE FACTS WHICH
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SUPPORT YOUR CONTENTION THAT THE REQUESTS ARE BURDENSOME AND
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OPPRESSIVE SUCH AS THE PARTICULAR DOCUMENTS REQUESTED ARE NOT
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SPECIFICALLY DESCRIBED NOR ARE THE CATEGORIES OF DOCUMENTS
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15 REASONABLY PARTICULARIZED.

16 The Opposition shall be based on this Opposition, the attached memorandum of points and
17
authorities, the declaration of ___________and exhibits attached thereto, on the complete files and
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records of this action, and on such other oral and/or documentary evidence as may be presented at the
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hearing on the Motion.
20

21 Dated________________ _______________________________________________
ANY ATTORNEY OR PARTY
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Be sure to modify these paragraphs to suit your individual
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25 situation. Do NOT just use the wording here unless it definitely applies
26
to your particular situation. Remember that YOUR OPPOSITION
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OPPOSITION TO MOTION TO COMPEL FURTHER REPONSES TO REQUESTS FOR DOCUMENTS

1 MUST BE SERVED AND FILED AT LEAST NINE (9) COURT
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DAYS BEFORE THE HEARING. Court days means Monday through
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Friday, except for Court holidays. You should serve your opposition by
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6 personal delivery or overnight mail. See Code of Civil Procedure

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Section 1005 for more details.
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OPPOSITION TO MOTION TO COMPEL FURTHER REPONSES TO REQUESTS FOR DOCUMENTS

1 MEMORANDUM OF POINTS AND AUTHORITIES

2 I.
3
STATEMENT OF FACTS
4
This case arises from LIST CAUSES OFACTION OF COMPLAINT. Plaintiff filed suit
5
against Defendant____________ on or about __________. See Plaintiff’s Complaint on file with the
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7 Court.

8 ____________ opposes the motion to compel and contends that the motion should be
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denied on the grounds that:
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The requests for production of documents are objectionable in that the documents requested
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clearly do not relate to the claim or defense of the party seeking discovery or of any other party to the
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13 action as required by Code of Civil Procedure § 2017.010; The requests for production of document

14 are unduly burdensome and oppressive in that LIST HERE THE FACTS WHICH SUPPORT
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YOUR CONTENTION THAT THE REQUESTS ARE BURDENSOME AND OPPRESSIVE
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SUCH AS THE PARTICULAR DOCUMENTS REQUESTED ARE NOT SPECIFICALLY
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DESCRIBED NOR ARE THE CATEGORIES OF DOCUMENTS REASONABLY
18

19 PARTICULARIZED.

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motion-to-compel-further-responses-to-documents-for-california
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OPPOSITION TO MOTION TO COMPEL FURTHER REPONSES TO REQUESTS FOR DOCUMENTS