Sample Motion to Strike Alter Ego Allegations in California

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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, and the entire complaint 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 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 is 16 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority and a proof of service by mail.  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.