Sample motion for sanctions under Code of Civil Procedure section 128.5 in California

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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 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.