Sample Opposition to Motion to Strike Punitive Damages in California

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This sample motion to strike punitive damages allegations in California is filed on the grounds that (1) the Motion to Strike is based on extrinsic evidence outside of the pleadings,  (2) that the complaint alleges sufficient facts to state a claim for punitive damages, and(3) that the Motion to Strike alleges a higher pleading standard for punitive damage claims than what is required under California law. The sample is 11 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority 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.