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    Sample Motion To Reopen Discovery in California

    Uploaded by

    Stan Burman
    This sample motion to reopen discovery in California is filed pursuant to Code of Civil Procedure section 2024.050(a) on the grounds that (1) the Court recently continued the trial date; (2) an order reopening discovery is necessary due to the fact that the moving party has a need to conduct additional discovery to assist in trial preparation and to prosecute the cross-complaint, and (3) the moving party has just filed an amendment to their complaint or cross-complaint substituting the true name of a defendant in place of a Doe or Roe defendant. The sample motion on which this preview is based is 11 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service. The author is an entrepreneur and retired litigation paralegal that worked in California and Federal litigation from January 1995 through September 2017. Note that the author is NOT an attorney and no guarantee or warranty is provided.

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    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd

    Sample Motion To Reopen Discovery in California

    Uploaded by

    Stan Burman
    6K views3 pages
    This sample motion to reopen discovery in California is filed pursuant to Code of Civil Procedure section 2024.050(a) on the grounds that (1) the Court recently continued the trial date; (2) an order reopening discovery is necessary due to the fact that the moving party has a need to conduct additional discovery to assist in trial preparation and to prosecute the cross-complaint, and (3) the moving party has just filed an amendment to their complaint or cross-complaint substituting the true name of a defendant in place of a Doe or Roe defendant. The sample motion on which this preview is based is 11 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service. The author is an entrepreneur and retired litigation paralegal that worked in California and Federal litigation from January 1995 through September 2017. Note that the author is NOT an attorney and no guarantee or warranty is provided.

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    Sample Motion to Reopen Discovery in California

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    This sample motion to reopen discovery in California is filed pursuant to Code of Civil Procedure section 2024.050(a) on the grounds that (1) the Court recently continued the trial date; (2) an order reopening discovery is necessary due to the fact that the moving party has a need to conduct additional discovery to assist in trial preparation and to prosecute the cross-complaint, and (3) the moving party has just filed an amendment to their complaint or cross-complaint substituting the true name of a defendant in place of a Doe or Roe defendant. The sample motion on which this preview is based is 11 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service. The author is an entrepreneur and retired litigation paralegal that worked in California and Federal litigation from January 1995 through September 2017. Note that the author is NOT an attorney and no guarantee or warranty is provided.

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
    6K views3 pages

    Sample Motion To Reopen Discovery in California

    Uploaded by

    Stan Burman
    This sample motion to reopen discovery in California is filed pursuant to Code of Civil Procedure section 2024.050(a) on the grounds that (1) the Court recently continued the trial date; (2) an order reopening discovery is necessary due to the fact that the moving party has a need to conduct additional discovery to assist in trial preparation and to prosecute the cross-complaint, and (3) the moving party has just filed an amendment to their complaint or cross-complaint substituting the true name of a defendant in place of a Doe or Roe defendant. The sample motion on which this preview is based is 11 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service. The author is an entrepreneur and retired litigation paralegal that worked in California and Federal litigation from January 1995 through September 2017. Note that the author is NOT an attorney and no guarantee or warranty is provided.

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
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    At a glance
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    The document discusses reopening discovery in a legal case and modifying discovery deadlines.

    The motion requests that the court reopen discovery to allow additional time for the defendant to prepare for trial and respond to an amended cross-complaint.

    The motion argues that additional discovery is needed due to a continued trial date and an amended cross-complaint substituting a real party's name.

    1 Any Attorney or Party

    Any Street
    2 Any Town, CA 55555

    3 714-555-5555

    4 Any Attorney or Party

    8 Superior Court of the State of California

    9 For the County of _________________

    10

    11 Any Plaintiff, ) Case No.


    )
    12 Plaintiff, ) NOTICE OF MOTION AND MOTION TO REOPEN
    vs. ) DISCOVERY; MEMORANDUM OF POINTS AND
    13 ) AUTHORITIES; DECLARATION
    ) OF____________; EXHIBITS
    14 Any Defendants, and DOES 1-5, inclusive, )
    )
    15 Defendants. )
    ) DATE:
    16 ) TIME:
    ) PLACE:
    17 )
    )
    18 )
    )
    19 )
    )
    20

    21 To subscribe to my FREE weekly legal newsletter visit


    22

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    http://freeweeklylegalnewsletter.gr8.com/ and enter your e-mail
    24
    address.
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    28 - 1

    NOTICE OF MOTION AND MOTION TO REOPEN DISCOVERY


    1 To view over 300 sample legal documents sold by LegalDocsPro
    2

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    visit: http://www.scribd.com/LegalDocsPro
    4 TO: ALL INTERESTED PARTIES AND THEIR RESPECTIVE ATTORNEYS OF
    5
    RECORD:
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    PLEASE TAKE NOTICE THAT on ____________, 20__, at _______.m. or as soon
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    thereafter as the matter may be heard, in Department ________ of the above-entitled court, located at

    9 ________________________, _________, ____________ will and hereby does move this Court:

    10 will and hereby does move this Court for an order reopening discovery in the above-entitled action.
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    This motion is brought pursuant to Code of Civil Procedure 2024.050(a) on the grounds that
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    (1) the Court continued the trial date to __________ at ________.M. in Dept. __ of the above-entitled
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    Court; (2) an order reopening discovery is necessary due to the fact that_____________________,
    14

    15 has a need to conduct additional discovery to assist him in trial preparation in order to defend against

    16 the complaint and to prosecute his cross-complaint, and (3) _______________________has just filed
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    an amendment to his cross-complaint substituting the true name of ______ in place of Roe Number 1
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    and has a need to propound discovery to _________ once she has made an appearance.
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    The motion shall be based upon this notice of motion and motion, the attached memorandum
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    21 of points and authorities, the attached declaration of ____________ and Exhibits attached thereto, the

    22 records and files of this action, and on such other and further oral and/or documentary evidence as
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    may be presented at the hearing on this motion.
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    NOTICE OF MOTION AND MOTION TO REOPEN DISCOVERY


    1 Be sure to modify these paragraphs to suit your individual
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    situation. Do NOT just use the wording here unless it definitely applies
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    to your particular situation.
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    Dated________________ ___________________________________________________
    ANY ATTORNEY OR PARTY
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    To purchase the entire 11 page document visit:
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    https://legaldocspro.myshopify.com/products/sample-motion-to-reopen-
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    11 discovery-in-california
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    NOTICE OF MOTION AND MOTION TO REOPEN DISCOVERY

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