Sample Opposition to Motion for Summary Judgment in California

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This sample opposition to a motion for summary judgment in California is made on the grounds that there are triable issues of material fact which preclude summary judgment. The sample 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 separate statement, sample declaration and proposed order. 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.