1 Any Attorney or Party

Any Street
2 Any Town, CA 55555

3 714-555-5555

4 Any Attorney or Party

8 UNITED STATES BANKRUPTCY COURT

9 ________ DISTRICT OF ______

10

11 IN RE: ________________, ) Case No.

)
12 Debtors, ) Chapter 7
)
13 Any Plaintiff ) Adv. Proc No.
)
14 Plaintiff, )
NOTICE OF MOTION AND MOTION FOR
)
JUDGMENT ON THE PLEADINGS;
15 vs. )
MEMORANDUM OF POINTS AND AUTHORITIES
)
16 Any Defendant, )
) DATE:
17 Defendant. ) TIME:
) PLACE
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)
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)
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)
21 )

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NOTICE OF MOTION AND MOTION FOR JUDGMENT ON THE PLEADINGS
 1 visit: http://www.scribd.com/LegalDocsPro Be sure to remove this
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notice and all other notices before using this document.
4 PLEASE TAKE NOTICE that on ________, at ______M. in Courtroom _____ of the
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above-entitled Court located at ___________________________, _____________ will move this
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Court for an Order granting judgment on the pleadings.
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This Motion will be made pursuant to Federal Rule of Civil Procedure 12(c) and Federal

9 Rule of Bankruptcy Procedure 7012(c) on the grounds that the complaint filed by Plaintiff

10 ______________fails to state sufficient facts to state any claim for relief against Defendant, hence
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there are no triable issues of material fact and Defendant is entitled to judgment as a matter of law.
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This motion shall be based upon this Notice, the attached Memorandum of Points and
13
Authorities, the complete files and records of this action, and such other and further oral and
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15 documentary evidence as may be presented at the hearing on this Motion.

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Dated_________________________ _______________________________________
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Any Attorney or Party
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NOTICE OF MOTION AND MOTION FOR JUDGMENT ON THE PLEADINGS
 1 MEMORANDUM OF POINTS AND AUTHORITIES
2 I.
3
STATEMENT OF FACTS
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Plaintiff filed their complaint against Defendants on _____________ with causes of action for
5

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______________________________________. See complaint on file.

7 Defendant moves for judgment on the pleadings on the grounds that the complaint filed by

8 plaintiff ______________fails to state sufficient facts to state any claims for relief against defendant,
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hence there are no triable issues of material fact and Defendant is entitled to judgment as a matter of
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law.
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Defendant contends that the complaint is deficient as it does not meet the particularity
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13 requirements of Federal Rule of Civil Procedure 9(b) or California law, and is barred by the

14 three year statute of limitations for fraud in California.

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NOTICE OF MOTION AND MOTION FOR JUDGMENT ON THE PLEADINGS