Sample motion to compel compliance with deposition subpoena in California.

Sample Motion to Compel Compliance with Deposition Subpoena in California

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Sample Motion to Compel Compliance with Deposition Subpoena in California.

This sample motion to compel compliance with a deposition subpoena in California is used when a party has served a deposition subpoena for production of business records on a NON-PARTY to the action pursuant to Code of Civil Procedure Section 2020.510 and requested both their attendance at the deposition and production of documents and they failed to appear for the deposition. 

This sample motion is made pursuant to Code of Civil Procedure section 2025.450 and requests that the court compel the non-party deponent to appear for deposition and produce the documents requested in the deposition subpoena for production of business records.

The sample has been revised and updated in March 2018, is 16 pages and includes,

  • Brief instructions,
  • Memorandum of points and authorities with citations to case law and statutory authority,
  • Sample meet and confer 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.