Sample Opposition to Motion to Amend Judgment to Add Alter Ego in California

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This sample opposition to a motion to amend a judgment to add a judgment debtor under alter ego liability under Code of Civil Procedure section 187 is filed on several grounds including (1) that the original judgment was obtained by default thus the alleged alter ego did not have control over the litigation, (2) that the motion to amend is not supported by any credible and substantial evidence that would support a finding of alter ego liability in that no unity of interest and ownership is shown or other evidence of a disregard for corporate formalities, and (3) that the motion to amend  is not timely. The sample is 12 pages and includes brief instructions, a memorandum of points and authorities with citations to case law supporting the opposition, sample declaration and proof of service. The author is a freelance paralegal that has worked in California and Federal litigation since 1995. Note that the author is NOT an attorney and no guarantee or warranty is provided.