Sample motion to dismiss on the grounds of inconvenient forum in California

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This sample motion to dismiss on the grounds of an inconvenient forum in California is filed under Code of Civil Procedure sections 410.30 and 418.10. The sample motion is filed on the grounds that California is a very inconvenient forum as the Defendant is not a resident of California and never has been, and that the great majority of witnesses and evidence are located outside of California. The sample motion also requests in the alternative that the Court stay the entire action, is 12 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.