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 MOTION AND MOTION TO REOPEN
vs. ) DISCOVERY; MEMORANDUM OF POINTS AND
13 ) AUTHORITIES; DECLARATION
) OF____________; EXHIBITS
14 Any Defendants, and DOES 1-5, inclusive, )
)
15 Defendants. )
) DATE:
16 ) TIME:
) PLACE:
17 )
)
18 )
)
19 )
)
20

21 To subscribe to my FREE weekly legal newsletter visit

22

23
http://freeweeklylegalnewsletter.gr8.com/ and enter your e-mail
24
address.
25

26

27

28 - 1

NOTICE OF MOTION AND MOTION TO REOPEN DISCOVERY

 1 To view over 300 sample legal documents sold by LegalDocsPro
2

3
visit: http://www.scribd.com/LegalDocsPro
4 TO: ALL INTERESTED PARTIES AND THEIR RESPECTIVE ATTORNEYS OF
5
RECORD:
6
PLEASE TAKE NOTICE THAT on ____________, 20__, at _______.m. or as soon
7

8
thereafter as the matter may be heard, in Department ________ of the above-entitled court, located at

9 ________________________, _________, ____________ will and hereby does move this Court:

10 will and hereby does move this Court for an order reopening discovery in the above-entitled action.
11
This motion is brought pursuant to Code of Civil Procedure 2024.050(a) on the grounds that
12
(1) the Court continued the trial date to __________ at ________.M. in Dept. __ of the above-entitled
13
Court; (2) an order reopening discovery is necessary due to the fact that_____________________,
14

15 has a need to conduct additional discovery to assist him in trial preparation in order to defend against

16 the complaint and to prosecute his cross-complaint, and (3) _______________________has just filed
17
an amendment to his cross-complaint substituting the true name of ______ in place of Roe Number 1
18
and has a need to propound discovery to _________ once she has made an appearance.
19
The motion shall be based upon this notice of motion and motion, the attached memorandum
20

21 of points and authorities, the attached declaration of ____________ and Exhibits attached thereto, the

22 records and files of this action, and on such other and further oral and/or documentary evidence as
23
may be presented at the hearing on this motion.
24

25

26

27

28 - 2

NOTICE OF MOTION AND MOTION TO REOPEN DISCOVERY

 1 Be sure to modify these paragraphs to suit your individual
2

3
situation. Do NOT just use the wording here unless it definitely applies
4
to your particular situation.
5

6
Dated________________ ___________________________________________________
ANY ATTORNEY OR PARTY
7

8
To purchase the entire 11 page document visit:
9
https://legaldocspro.myshopify.com/products/sample-motion-to-reopen-
10

11 discovery-in-california
12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28 - 3

NOTICE OF MOTION AND MOTION TO REOPEN DISCOVERY