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 DEMURRER AND DEMURRER TO
vs. ) COMPLAINT; MEMORANDUM OF POINTS AND
13 ) AUTHORITIES; DECLARATION OF
) ______________ REGARDING COMPLIANCE
14 Any Defendants, and DOES 1-5, inclusive, ) WITH MEET AND CONFER REQUIREMENTS OF
) CODE OF CIVIL PROCEDURE 430.41
15 Defendants. )
) DATE:
16 ) TIME:
) DEPT:
17 )
)
18 )
)
19

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TO: ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
27
PLEASE TAKE NOTICE that on _______________ at ___________. in Department ___of
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NOTICE OF DEMURRER AND DEMURRER TO COMPLAINT

 1

2 the above entitled court, located at ____________________________________________,

3
Defendant, _________________________, will and hereby does move the Court for an order
4
sustaining special demurrers to the demurrers to the first, second, third and fourth causes of action in
5

6
Plaintiffs Complaint.

7 The moving party has complied with the meet and confer requirements of Code of Civil

8 Procedure 430.41 as shown by the attached declaration.

9
This demurrer is made pursuant to Code of Civil Procedure 430.10(f) on the grounds that
10
the first, second, third and fourth causes of action in Plaintiffs Complaint are uncertain because they
11
are vague and ambiguous in that STATE THE REASONS THAT THE CAUSES OF ACTION
12

13 ARE VAGUE AND AMBIGUOUS.

14 The Demurrer shall be based on this notice of demurrer and the attached demurrer, the
15
attached memorandum of points and authorities, the attached declaration of ________ regarding
16
compliance with the meet and confer requirements of Code of Civil Procedure 430.41, on the
17
complete files and records of this action, and on such other oral and/or documentary evidence as may
18

19 be presented at the hearing on the Motion.

20
Dated________________ ___________________________________________________
21
ANY ATTORNEY OR PARTY
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NOTICE OF DEMURRER AND DEMURRER TO COMPLAINT

 1 DEMURRER TO PLAINTIFFS COMPLAINT
2 This demurrer is made pursuant to Code of Civil Procedure 430.10(f) on the grounds that the
3
first, second, third and fourth causes of action in Plaintiffs Complaint are uncertain because they are
4
vague and ambiguous to such a degree that the Moving Defendants are unable to respond.
5

6
Moving Defendants hereby specially demur to Plaintiffs Complaint on each of the following

7 grounds:

8 DEMURRER TO FIRST CAUSE OF ACTION:

9
1. The first cause of action for _____________ is uncertain as well as vague and
10
ambiguous to such a degree that the Moving Defendants are unable to respond in that STATE THE
11
REASONS THAT THE CAUSE OF ACTION IS VAGUE AND AMBIGUOUS.
12

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NOTICE OF DEMURRER AND DEMURRER TO COMPLAINT