Sample Motion to Compel Production of Documents for California

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This sample motion to compel production of documents for California is used when a NON-party to the lawsuit has refused to produce documents after being served with a deposition subpoena for production of business records. This motion should only be used to compel a NON-party to the lawsuit to produce documents. The sample motion has been revised and updated in December 2016 and includes 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.