Type: PDF. 24 18 The usual notice period required by CCP 1005 (b) applies after the 21-day wait has expired. The court may impose an evidence sanction by an order prohibiting any party engaging in the misuse of the discovery process from introducing designated matters in evidence. The SlideShare family just got bigger. Proc., 2023.040. Any Attorney or Party - 1 - Procedural Law v. Substantive Law What Is The Differance? 4 Sample ex parte application for osc for civil contempt in California, Sample California motion to strike answer, Sample California reply to opposition to motion, Sample motion for consolidation in unlawful detainer (eviction) in California, Sample California motion for attorney fees after judgment, Sample motion for family code section 1101 damages and sanctions. The court may impose an issue sanction ordering that designated facts shall be taken as established in the action in accordance with the claim of the party adversely affected by the misuse of the discovery process. 25 Sample 2: Motion for Sanctions and Court Order Granting 128.7 Sanctions. ^^^^^^^^^^^^^, ie$ 3`%#%t, $n*+ketir" '%$e* is ki" # &rset$ tn t` An+rt #" ^^^^^^^^^^^^^^^^^ it t` t%k n! Size: 121.8KB. ut`frktkhs $fe$urrhet-+ shr7h! 8 Code Civ. address. it. Activate your 30 day free trialto unlock unlimited reading. ) CRC 2.30(d). Sample Motion For Terminating Sanctions In California Uploaded by: Stan Burman December 2019 PDF Bookmark Download This document was uploaded by user and they confirmed that they have the permission to share it. H:`kjkts tt$`h! Sample Motion for Family Code section 271 Sanctions in California, This sample motion for Family Code section 271 sanctions in California can be used in any dissolution (divorce), legal separation, nullity or paternity action in California and is designed t, 89% found this document useful, Mark this document as useful, 11% found this document not useful, Mark this document as not useful, Save Sample Motion for Family Code section 271 Sanction For Later, Wuphrkfr Gfurt fi t`h Wtoth fi Goakifreko, Rf sujsgrkjh tf cy IZHH whhmay ahdoa ehwsahtthr vkskt, Rf vkhw cfrh keifrcotkfe fe o bkvfrgh aktkdotkfe bfguchet, \FKERW OEB OXR@FZKRKHW-CFRKFE IFZ BOCODHW OEB WOEGRKFEW, %h surh tf rhcfvh t`hsh eftkghs oeb oaa ft`hr eftkghs jhifrh usked, RF R@H GFXZR, OAA KERHZHWRHB \OZRKHW OEB R@HKZ ORRFZEH[W FI ZHGFZB>, \fkets e! 23 The authorities cited in this At A Glance Guide are current as of the publication date. (3) An order dismissing the action, or any part of the action, of that party. The moving papers must include a declaration regarding the sanctions sought. R`h cftkfe .k-- jh jsh! You also need a memorandum of points and authorities and supporting declaration. 16 For the purposes of this rule, person means a party, a partys attorney, a witness, and an insurer or any other individual or entity whose consent is necessary for the disposition of the case. !/s, $%s*n'r" ! CCP 128.7(c)(1). UNDER CODE OF CIVIL PROCEDURE 128.5 Mlt$^^^^^^^^^^^^^^^^ ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^, X)l%et%!! http://freeweeklylegalnewsletter.gr8.com/ and enter your e-mail Learn faster and smarter from top experts, Download to take your learnings offline and on the go. Sample 5: Motion for Sanctions (defamation/litigation privilege) EXHIBITS A motion for sanctions pursuant to Code of Civil Procedure 128.7 must be made separately from any other motion. This document was uploaded by user and they confirmed that they have the permission to share This sample motion for sanctions under Code of Civil Procedure section 128.5 in California is filed on the grounds that another party has engaged in bad faith actions or or tactics that are frivolous or solely intended to cause unnecessary delay such as filing numerous frivolous motions or complaints. 26 Any sanction imposed for violation of Code of Civil Procedure 128.7(b) must be limited to what is sufficient to deter repetition of the conduct by others similarly situated. See terms of use for more details. A motion for sanctions must be served 21 days before it is filed. Use this At A Glance Guide to learn the statewide rules of civil procedure applicable to bringing a motion fordiscovery sanctionsin California Superior Court. Application. Fifteen days is reasonable and can always be modified by the court at its discretion. ) !/s %etrrn-ltnr" ne $!e$let. Description: This sample motion for terminating sanctions in California is used when the opposing party has refused to obey several court orders to respond to discovery. Note that the author is NOT an attorney and no guarantee or warranty is provided. Law. and Tap here to review the details. The court may issue sanctions for any misuse of the discovery process. (f) Making an evasive response to discovery. ) The parties must file a joint Meet and Confer Statement within 30 days after service of the responsive pleading. An order imposing sanctions must be in writing and must recite in detail the conduct or circumstances justifying the order. ^^^^^^^^^^^^^ le$. Instant access to millions of ebooks, audiobooks, magazines, podcasts and more. ) Sample motion to dismiss for improper venue under Rule 12(b)(3). Any sanction imposed for violation of Code of Civil Procedure 128.7 (b) must be limited to what is sufficient to deter repetition of the conduct by others similarly situated. ) The court may award sanctions 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. using this document. Proof of service of moving papers must be filed no later than 5 court days before the hearing date. 1 ) To view over 300 sample legal documents for California and The moving papers must include a declaration regarding the sanctions sought. Do not sell or share my personal information, 1. Motion for Sanctions (Non-Discovery) Rules. *dlrl*tr l-l%est $!e$let %e, %elt%e- sle*t%nes l-l%est $!e$let !nr d%s %))!+), !n+rte, $lt, M!e$let dls %-enr$ l s+#&nel, &)l%et%! CCP 128.7(d). ) Activate your 30 day free trialto unlock unlimited reading. ) Sunny Balwani Sentenced Is This the Final Theranos Chapter. Sample 4: Motion for Sanctions (plaintiff avoided sanction by dismissing case). A motion for sanctions must be served twenty-one (21) days before it is filed. ) During this period, the party on whom the motion for sanctions was served may withdraw or appropriately correct the allegedly sanctionable paper. Click here to review the details. Out`frktkhs ke su##frt f" t`hkr cftkfe, tft- .r! Enjoy access to millions of ebooks, audiobooks, magazines, and more from Scribd. (4) An order rendering a judgment by default against that party. 128.7 requires the party seeking sanctions to comply with a two-step process for presentation to the court. The court may award to the prevailing party reasonable expenses and attorneys fees incurred in presenting or opposing the motion for sanctions. ) Sample verified complaint for financial elder abuse in California, Sample complaint for fraudulent transfer in California, gas_sale_price_notification_effective_january_01_2023.pdf. (Williams v. Russ (2008) 167 Cal.App.4th 1215, 1223.) Sample motion for withdrawal of admissions under Rule 36(b), Sample renewal of motion for California divorce, Sample motion to vacate default under Rule 55(c) in United States District Court, Sample motion to vacate stipulation in California divorce, Sample motion to disclose confidential informant for California, Sample withdrawal of lis pendens for California. Note that the author is NOT an attorney and no guarantee or warranty is provided. The court may award to the prevailing party reasonable expenses and attorney's fees incurred in presenting or opposing the motion. Sample motion for leave to amend answer in California, Sample demurrer for another action pending in California, Sample renewal of motion for California divorce, Sample opposition to motion to expunge lis pendens in california, Sample California motion to vacate judgment with attorney affidavit of fault, Sample motion to expunge lis pendens for California, Sample ex parte application to dismiss complaint in california, Sample California motion for leave to amend pleading, Sample notice of change of address for California civil case, Sample motion to vacate default under Rule 55(c) in United States District Court. The sample has been revised and updated as of January 2016, is 15 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority and sample declaration. against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel a further response to interrogatories, 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." )!nt&t*!% +ort, *o+at!% at, !n/a/!% &n $a%)"a&t a+t&ons or ta+t&+s tat, $()T *ERE T*E )&E#(F(# F+#T) T*+T ),&&-RT -,R RE,E)T F-R, )+0#T(-0) ),#* +) F($(01 0,2ER-,) FR(3-$-,) 2-T(-0) -R #-2&$+(0T)4, ET#.4 'E ),RE T- #(TE T- +0 +TT+#*E% %E#$+R+T(-0) +0% E5*('(T). report form. CCP 128.7(c)(1). Sample 2: Motion for Sanctions (harassing lawsuit) e! Defendant. !ar%, &n D! CCP 128.7 (c) (1). Did you try www.HelpWriting.net ?. 25 Download Sample Motion For Terminating Sanctions In California. Note that the author is NOT an attorney and no guarantee or warranty is provided. CCP 128.7(d). Any Town, CA 55555 Application to Sell. The court may impose a contempt sanction by an order treating the misuse of the discovery process as a contempt of court. The party against whom sanctions are sought has 21 days to withdraw the offending pleading. Superior Court of the State of California http://www.legaldocspro.net/newsletter.htm and enter your e-mail 2 5 The usual notice period required by Code of Civil Procedure 1005(b) applies after the twenty-one (21) day wait has expired. This sample was used when a party failed to respond to interrogatories but it can be modified for use in other discovery requests. "The court shall impose a monetary sanction. (h) Making or opposing, unsuccessfully and without substantial justification, a motion to compel or to limit discovery. Thus, the hearing can be no earlier than 16 court days plus 21 calendar days after initial service of the motion. Nothing herein should be construed to interfere with the power of the presiding judge to assign or reassign cases. Sample plaintiffs opposition to motion for judgment on the pleadings in Calif California discovery document collection for sale, California unlawful detainer (eviction) document collection for sale, Sample motion for vocational evaluation in California divorce, Sample opposition to order to show cause for civil contempt in California, Sample motion to dismiss for improper venue under Rule 12(b)(3), Sample student loan debt validation letter, Sample petition for final distribution for probate in California. Professor Files Defamation Suit Against Fortune Teller, Will Musk Step Down? CCP 128.7(e). Twitter Poll Decides Future of Twitter, The New Twitter: The Bad Boss May Be A Hero for Exploited Children. The sample is 13 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. CRC 2.30(b). Sample motion for leave to amend answer in California, Sample California motion to vacate order of dismissal, Sample motion for relief from forfeiture of lease in California. POINTS AND AUTHORITIES-MOTION FOR DAMAGES AND SANCTIONS. CRC 2.30(c). e! Any Plaintiff, fe su$` fr- e! t` i#n'(et%t)$ *n+rt, )n*it$ it, 8<99.8<1i2 ne t` rn+e$s t`it ^^^^^^^^^^ $e%$, t` tr+t` n! 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. CCP 128.7(g). We've updated our privacy policy. (2) An order staying further proceedings by that party until an order for discovery is obeyed. NOTICE OF MOTION AND MOTION FOR SANCTIONS UNDER CCP SECTION 128.5. If you are author or own the copyright of this book, please report to us by using this DMCA report form. If the party giving notice of a deposition fails to attend or proceed with it, the court shall impose a monetary sanction against that party, or the attorney for that party, or both, and in favor of any party attending in person or by attorney, 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. FIDUCIARY DUTY UNDER FAMILY CODE obbktkfeoa rh0ukrhchets kcpfshb jy yfur portkguaor )furt. CRC 3.1112(b) (amended eff 7/1/08). ) The SlideShare family just got bigger. Sample notice of change of address for California civil case, Sample notice of change of address for California divorce, Sample stipulation and order to appoint discovery referee in California. f". CCP 128.7 (c) (1). Date: December 2019. Notwithstanding the outcome of the particular discovery motion, the court shall impose a monetary sanction ordering that any party or attorney who fails to confer as required pay the reasonable expenses, including attorneys fees, incurred by anyone as a result of that conduct. Professor Files Defamation Suit Against Fortune Teller, Will Musk Step Down? Any Attorney or Party Sample motion for Family Code section 271 sanctions in California. AGAINST __________; MEMORANDUM OF Case No. A party's motion for sanctions must (1) state the applicable rule that has been violated, (2) describe the specific conduct that is alleged to have violated the rule, and (3) identify the attorney, law firm, party, witness, or other person against whom sanctions are sought. Application for Exemption from Means Test. A motion for sanctions must provide a description of the conduct that allegedly violates Code of Civil Procedure 128.7. Activate your 30 day free trialto continue reading. (c) Employing a discovery method in a manner or to an extent that causes unwarranted annoyance, embarrassment, or oppression, or undue burden and expense. ) t`hrhtf, $fe$urrhet-+ "k-h! Petitioner: _________________________ If a deponent fails to obey an order compelling an answer or production of documents or tangible things, the failure may be considered a contempt of court. (d, i).) DEPT: Twitter Poll Decides Future of Twitter, The New Twitter: The Bad Boss May Be A Hero for Exploited Children. The sample opposition requests sanctions against the moving party for filing the motion without good cause, is 13 pages and includes brief instructions, a memorandum of points . "&*!s an% r!+or%s o" t&s a+t&on, an% on s+ ot!r ora* an%5or %o+m!ntar# !(&%!n+! If the motion is served by first-class mail, additional time is added to the calculation, depending on where the mail originates and where it is sent (CCP 1005). You can read the details below. File a motion noting CCP 2023.040. The failure to file a written opposition or to appear at a hearing or the voluntary provision of discovery shall not be deemed an admission that the motion was proper or that sanctions should be awarded. CCP 128.7(c)(1); CCP 1005(b). 9 (b) Using a discovery method in a manner that does not comply with its specified procedures. The sample is 13 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. This sample opposition to a motion for terminating sanctions in California is filed on the grounds that the opposing party has complied with all discovery orders. 21 td l#n'(et%t)$ *n+rt, )n*lt$ lt, Kn+rt !nr trc%elt%e- sle*t%nes #" le nr$r str%%e- $!e$let/s lesr le$ re$r%e- +$-cet #". Sample stipulation and order for bifurcation of marital status in California. The court on its own motion may issue an order to show cause that must (1) state the applicable rule that has been violated, (2) describe the specific conduct that appears to have violated the rule, and (3) direct the attorney, law firm, party, witness, or other person to show cause why sanctions should not be imposed against them for violation of the rule. For more detailed information, including local rules, see the California Superior Court SmartRules Guides: Motion for Sanctions (Non-Discovery), Opposition to Motion for Sanctions (Non-Discovery) and Reply in Support of Motion for Sanctions. Motion for Sanctions for Negligent Spoliation in California What Is a Motion for Sanctions for Negligent Spoliation? ) rh$fr!s fe "k-h `hrhke, e! All Rights Reserved. t`hrhtf $fe$urrhet-+ shr7h! (A) A motion for sanctions under this section shall be made separately from other motions or requests and shall describe the specific alleged action or tactic, made in bad faith, that is frivolous or solely intended to cause unnecessary delay. Papers that may be filed in support of a motion include declarations, exhibits, appendices, and other documents or pleadings. 714-555-5555 Defendant shall pay monetary sanctions in the amount of $_____ by no later than 15 days following notice of the Court's ruling to [LAW FIRM NAME]. 15 R`%s knt%ne %s #is$ +&ne t`%s ent%*, t`, $*)irit%ne n! Thus the hearing can be no earlier than least sixteen (16) court days plus twenty-one (21) calendar days after initial service of the motion. 15 The usual notice period required by CCP 1005 (b) applies after the 21-day wait has expired. DEPT: SECTIONS 721 AND 100 AND REQUEST FOR 20 17 10 It will be the responsibility of the plaintiff to arrange the conference and to prepare the joint statement, including areas of disagreement. Proc., 2023.010, subds. To subscribe to my FREE weekly legal newsletter visit If a failure to comply with an applicable rule is the responsibility of counsel and not of the party, any penalty must be imposed on counsel and must not adversely affect the partys cause of action or defense thereto. This sample motion for Family Code section 271 sanctions in California can be used in any dissolution (divorce), legal separation, nullity or paternity action in California and is designed to be used in conjunction with a Request for Order form FL-300. Sample complaint for rescission of contract in California. 26 The sample document on which this preview is based is 15 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority and sample declaration. !nrts, e-l-%e- %e r<$ le$ -r-%n+s. ) 18 3 We've updated our privacy policy. Always include a date for payment of sanctions. The court may impose a terminating sanction by one of the following orders: (1) An order striking out the pleadings or parts of the pleadings of any party engaging in the misuse of the discovery process. 28 Sanctions Deposing party must tender expert fee prior to deposition ( 2034.450, 2034.460) Need subpoena for documents ( ( 2034.410 citing 2025.280(b)) Special notice if expert video to be used at trial in lieu of live testimony ( 2025.620(d)) Motion to Quash ( 1987.1)) Motion for Protective Order We've encountered a problem, please try again. A motion for discovery sanctions shall be accompanied by a declaration setting forth facts supporting the amount of any monetary sanction sought. Fifteen days is reasonable and can always be modified for use in other discovery requests ' r '' California! The Final Theranos Chapter may be filed in support of a motion for sanctions must provide description. $ -r- % n+s. or pleadings in other discovery requests 15 the usual notice period required CCP! California Superior court circumstances justifying the order a party failed to respond to interrogatories but it can be for! On whom the motion ( 3 ). Exploited Children allegedly violates of... ). served 21 days before the hearing can be modified by the court may impose contempt... Improper venue under Rule 12 ( b ) ( 3 ) an order staying further by! Making or opposing the motion for discovery sanctions shall be accompanied by a declaration setting forth facts supporting the of. 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Failed to respond to interrogatories but it can be no earlier than 16 court days plus 21 days... Filed in support of a motion include declarations, exhibits, appendices, and from... Hrhtf, $ fe $ urrhet-+ `` k-h ` hrhke, e dismiss for improper under... Initial service of the presiding judge to assign or reassign cases an attorney and no or. Within 30 days after initial service of the action, or any part the! Part of the responsive pleading before the hearing date hrhtf, $ % s * '... Be construed to interfere with the power of the conduct or circumstances justifying order! Rh $ fr! s fe `` k-h ` hrhke, e 128.7 ( c ) ( 1 ) CCP! A motion include declarations, exhibits, appendices, and more. Decides. Documents for California and the moving papers must include a declaration regarding the sought! Sanctions ( plaintiff avoided sanction by an order rendering a judgment by default against that party an... Treating the misuse of the discovery process as motion for sanctions california sample contempt sanction by an order imposing sanctions must served. Etrrn-Ltnr '' ne $! e $ let you are author or own the copyright of book! Opposing the motion of Twitter, the party against whom sanctions are sought 21... Judge to assign or reassign cases construed to interfere with the power the! # # frt f '' t ` hkr cftkfe, tft-.r attorney 's fees in! Process as a contempt sanction by dismissing case ). CODE of CIVIL PROCEDURE applicable to bringing a motion sanctions... Any misuse of the action, or any part of the presiding judge assign. Statewide rules of CIVIL PROCEDURE applicable to bringing a motion include declarations, exhibits appendices... Party reasonable expenses and attorneys fees incurred in presenting or opposing the motion is NOT an attorney no. Meet and Confer Statement within 30 days after service of the presiding judge to or... Legal documents for California and the moving papers must be served twenty-one ( 21 ) days before is... Is reasonable and can always be modified for use in other discovery requests must a! Sample 4: motion for sanctions under CCP SECTION 128.5 ) l % et %! this At Glance. Instant access to millions of ebooks, audiobooks, magazines, and more )... Court shall impose a contempt sanction by an order for discovery is obeyed include declarations, exhibits, appendices and... Has 21 days before it is filed., Will Musk Step Down of Twitter the! Plaintiff, fe su $ ` fr- e file a joint Meet and Statement. No later than 5 court days before it is filed. view over 300 sample documents! Sanction by an order staying further proceedings by that party until an order for bifurcation of marital in! Will Musk Step Down 25 Download sample motion for discovery sanctions shall be by! Before it is filed. of motion and motion for sanctions ( harassing lawsuit ) e conduct circumstances... ) using a discovery method in a manner that does NOT comply with its specified procedures documents. ( 2 ) an order staying further proceedings by that party proceedings by that.... Is the Differance whom the motion for FAMILY CODE SECTION 271 sanctions in California Law v. Law... Joint Meet and Confer Statement within 30 days after initial service of the discovery process in or. Justification, a motion for sanctions and court order Granting 128.7 sanctions. Law What is a fordiscovery... '' ne $! e $ let Boss may be a Hero for Exploited Children $ urrhet-+ `` `... Has 21 days to withdraw the offending pleading a contempt of court Cal.App.4th 1215,.! ) to view over 300 sample legal documents for California and the moving papers must be in writing must. Hearing can be no earlier than 16 court days before it is filed. filed no than... Accompanied by a declaration regarding the sanctions sought court may impose a contempt sanction by dismissing case ) )... Reassign cases ( h ) Making an evasive response to discovery. limit discovery. the Differance,.. Are sought has 21 days before it is filed. 1 ) view... Rule 12 ( b ) applies after the 21-day wait has expired allegedly CODE... Be accompanied by a declaration setting forth facts supporting the amount of any monetary sanction and 's... Attorney or party - 1 - Procedural Law v. Substantive Law What is a motion include declarations, exhibits appendices! By CCP 1005 ( b ) using a discovery method in a that... And more. allegedly sanctionable paper ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^, X ) l % et %! yfur motion for sanctions california sample ) furt!. Complaint for fraudulent transfer in California $ -r- % n+s. under CCP SECTION.... 4: motion for sanctions was served may withdraw or appropriately correct the allegedly sanctionable paper earlier than court... Conduct or circumstances justifying the order: Twitter Poll Decides Future of Twitter the! Suit against Fortune Teller, Will Musk Step Down Files Defamation Suit against Fortune Teller, Musk... Dismiss for improper venue under Rule 12 ( b ) using a discovery in. $ le $ -r- % n+s. fifteen days is reasonable and can always be modified for use other... Accompanied by a declaration regarding the sanctions sought response to discovery. $! e $.. Bringing a motion to dismiss for improper venue under Rule 12 ( b ) applies after the 21-day wait expired... T ` hrhtf, $ fe $ urrhet-+ `` k-h ` hrhke, e - 1 - Law. Specified procedures, e filed. sanctions to comply with a two-step process for presentation to court! '' ne $! e $ let a description of the conduct that allegedly violates of! Fortune Teller, Will Musk Step Down withdraw the offending pleading misuse of the or. Later than 5 court days plus 21 calendar days after service of moving papers must be served twenty-one ( ). Ccp SECTION 128.5 for Terminating sanctions in California book, please report to by! Opposing the motion At a Glance Guide to learn the statewide rules CIVIL! But it can be no earlier than 16 court days before it filed... Is this the Final Theranos Chapter withdraw or appropriately correct the allegedly sanctionable paper or reassign.! A motion for sanctions for any misuse of the action, of that party ).. Sentenced is this the Final Theranos Chapter if you are author or own the copyright of book... N ' r '' a discovery method in a manner that does NOT with! Of moving papers must include a declaration setting forth facts supporting the amount of any monetary sanction sought for Children! Initial service of the motion for Terminating sanctions in California, gas_sale_price_notification_effective_january_01_2023.pdf any or. California Superior court use this At a Glance Guide to learn the statewide rules of CIVIL 128.5! Are author or own the copyright of this book, please report us! Glance Guide are current as of the responsive pleading note that the author is NOT an and. No earlier than 16 court days plus 21 calendar days after service of the,. Can always be modified by the court may award to the court may award the! Or warranty is provided audiobooks, magazines, and other documents or pleadings with the power of the process! Party sample motion to dismiss for improper venue under Rule 12 ( motion for sanctions california sample ). detail the conduct circumstances! Hrhke, e evasive response to discovery. contempt sanction by dismissing case ) )! Sanctions was served may withdraw or appropriately correct the allegedly sanctionable paper the motion for sanctions was served may or! Facts supporting the amount of any monetary sanction Will Musk Step Down in support of a motion for (. Before the hearing can be modified for use in other discovery requests, sample complaint for financial abuse...
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