To designation of responding party and to his/her/its attorney of record:
NOTICE IS HEREBY GIVEN that on hearing date or as soon thereafter as the matter may be heard, in Department department number this court, located at Court Address, Sacramento, the party designation and name of moving party will, and hereby does, move for an order compelling party designation and name of responding party, to serve on him/her/it a response to the moving party's designation’s Requests for Production of Documents, set set number, which he/she/it served on party designation and name of responding party on date served , and will further move this court for an order requiring party designation and name of responding party, to pay a monetary sanction to designation of moving party. The motion will be made on the grounds that designation of responding party has failed to serve a timely response to the above-described Requests for Production of Documents.
The motion will be based on this notice of motion, on the declaration of NAME OF MOVING PARTY and the memorandum set forth below, on the records and file herein, and on such evidence as may be presented at the hearing of the motion.
NOTICE OF TENTATIVE RULING SYSTEM
Pursuant to Local Rule 1.06 (A) the court will make a tentative ruling on the merits of this matter by 2:00 p.m., the court day before the hearing. The complete text of the tentative rulings for the department may be downloaded off the court’s website. If the party does not have online access, they may call the dedicated phone number for the department as referenced in the local telephone directory between the hours of 2:00 p.m. and 4:00 p.m. on the court day before the hearing and receive the tentative ruling. If you do not call the court and the opposing party by 4:00 p.m. the court day before the hearing, no hearing will be held.
Name Of Moving Party
Party designation, In Pro Per
MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT FOR ORDER COMPELLING RESPONSES TO REQUEST FOR PRODUCTION AND FOR MONETARY SANCTIONS
PARTY DESIGNATION AND NAME OF RESPONDING PARTY HAS FAILED TO SERVE A TIMELY RESPONSE TO PARTY DESIGNATION AND NAME OF MOVING PARTY’S DEMAND FOR PRODUCTION OF DOCUMENTS, SET SET NUMBER, AND THUS THE COURT SHOULD MAKE AN ORDER COMPELLING A RESPONSE AND IMPOSING A MONETARY SANCTION FOR THE FAILURE TO RESPOND.