YOUR NAME
Your Address
City, State, ZIP
Phone Number

YOUR NAME, In Pro Per

SUPERIOR COURT OF CALIFORNIA
COUNTY OF COUNTY NAME

PLAINTIFF'S NAME,
	Plaintiff,
	vs.
DEFENDANT'S NAME,
	Defendant	)
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)	Case No.: Case Number 

NOTICE OF MOTION AND MOTION; MEMORANDUM OF POINTS AND AUTHORITIES; and DECLARATION OF MOVING PARTY IN SUPPORT OF MOTION TO COMPEL RESPONSES TO REQUESTS FOR PRODUCTION OF DOCUMENTS, SET SET NUMBER AND MONETARY SANCTION

Date: Date of Hearing
Dept. Department for Hearing
Time: Time of Hearing

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.

Dated: Date

By: ______________________
							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.

A. Party May Move for Order Compelling Response and for Monetary Sanction. When a party makes an inspection demand under Section 2031.010 of the Code of Civil Procedure and the party to whom the demand is directed fails to respond, the demanding party may move for an order compelling response and for a monetary sanction under Section 2023.030 of the Code of Civil Procedure ( Code Civ. Proc. § 2031.300).

B. Waiver of Objection to Demand. When the party to whom an inspection demand has been directed fails to serve a timely response to it, that party waives any objection to the demand, including one based on privilege or on the protection for work product under Section 2018.010 et seq. of the Code of Civil Procedure ( Code Civ. Proc. § 2031.300(a)).

C. Court Must Impose Monetary Sanction Absent Specified Findings. The court must impose a monetary sanction under Section 2023.030 of the Code of Civil Procedure against any party, person, or attorney who unsuccessfully opposes a motion to compel a response to an inspection demand, unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust (Code Civ. Proc. §§ 2023.030(a), 2031.300(c)).

D. Court May Impose Sanctions Despite Lack of Opposition to Motion to Compel Discovery. The court may award sanctions under the Discovery Act in favor of a party who files a motion to compel discovery, even though no opposition to the motion was filed, or opposition to the motion was withdrawn, or the requested discovery was provided to the moving party after the motion was filed (Cal. Rules of Ct., Rule 3.1030(a)).

Dated: Date

By: ______________________
							Name of Moving Party
							Party designation, In Pro Per

DECLARATION OF NAME OF MOVING PARTY IN SUPPORT FOR ORDER COMPELLING RESPONSES TO DISCOVERY REQUESTS AND FOR MONETARY SANCTIONS

I, NAME OF MOVING PARTY, declare:

1. I am the moving party's designation in the above entitled action.

2. On date requests were served I served my Requests for Production of Documents, Set set number, on the party designation and name of responding party. A true copy with proof of service is attached to this declaration as Exhibit A and made a part hereof.
3. I have not received any response to my Requests for Production of Documents, Set set number, from the responding party's designation. 
4. On Date , I had served the “meet and confer” letter attached with a proof of service, as Exhibit B, but have still not received any responses.
5. I ask that the court award sanctions of $amount of sanctions. I base my request for the imposition of a sanction on basis that it took me number of hours hours to research and prepare the instant motion. My hourly wage is $your wages per hour times number of hours listed above hours equals $hours times your wages. In addition, the motion filing fee for this motion was $filing fee. 

 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.

Dated: Date

By: ______________________
							Name Of Moving Party
							Party designation, In Pro Per

EXHIBIT A

EXHIBIT B