Sample Motion for Terminating Sanctions in California

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This sample motion for terminating sanctions in California is used when the opposing party has refused to obey several court orders to respond to discovery. This sample was used when a party failed to respond to interrogatories but it can be modified for use in other discovery requests. The sample has been revised and updated in December 2016, is 17 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. The author is a freelance paralegal that 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.