Sample motion to strike alter ego allegations in California.

Sample Motion to Strike Alter Ego Allegations in California

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Sample Motion to Strike Alter Ego Allegations in California.

This sample motion to strike alter ego allegations in California is used by a defendant to request that the court strike the alter ego allegations in a complaint or cross-complaint on the grounds that,

  • The alter ego allegations which appear through the complaint are factually devoid and in fact are merely generic boilerplate allegations which are insufficient to support an alter ego claim,
  • The entire complaint should be stricken as it is a sham complaint that was only filed to exert pressure on the defendant by attempting to impose personal liability on them to extract a settlement, or
  • In the alternative for an order striking the other specified portions of the complaint including on the grounds that the plaintiff has failed to allege sufficient facts to entitle them to an award of punitive and exemplary damages, and
  • The complaint requests attorney’s fees even though the allegations of the complaint do not support an award of attorney’s fees.

This sample motion has been revised and updated in January 2018, is 18 pages and includes,

  • Brief instructions,
  • Memorandum of points and authorities with citations to case law and statutory authority,
  • Sample declaration regarding compliance with the meet and confer requirements of Code of Civil Procedure section 435.5(a), and
  • Proof of service by mail. 

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.