1. 1 1ANY ATTORNEY
LAW OFFICES OF ANY ATTORNEY
2 12345 ANY STREET
3 ANY TOWN, CA 55555
213-555-5555
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Attorney for Defendants/Cross-Complainants
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
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FOR THE COUNTY OF LOS ANGELES
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13 ANY PLAINTIFF, ) CASE NO.
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14 Plaintiff, )
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v. ) OPPOSITION TO MOTION FOR
16 ) SUMMARY JUDGMENT;
ANY DEFENDANTS, ) MEMORANDUM OF POINTS
17 ) AND AUTHORITIES;
Defendants. ) SEPARATE STATEMENT OF
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) UNDISPUTED MATERIAL FACTS;
19 ____________________________________) DECLARATION OF ________
) EXHIBITS
20 AND RELATED CROSS-ACTIONS )
) DATE:
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) TIME:
22 ) DEPT:
____________________________________)
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24 To subscribe to my FREE California weekly legal newsletter visit
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OPPOSITION TO MOTION FOR SUMMARY JUDGMENT

2. 1 http://www.scribd.com/doc/27153403/Sample-Opposition-to-Motion-
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for-Summary-Judgment-in-California
4 Cross-Complainant, _________________________ (“Cross-Complainant”), herein submits
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its Opposition to Plaintiffs/Cross-Defendants Motion for Summary Judgment.
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The Opposition shall be based on this Opposition, the attached Memorandum of Points and
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Authorities, the Declaration of ________________________and Exhibits attached thereto, and the
9 Separate Statement of Undisputed Material Facts, concurrently filed and served, on the complete files
10 and records of this action, and on such other oral and/or documentary evidence as may be presented
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at the hearing on the Motion.
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Dated________________ ______________________________________________
13 ANY ATTORNEY
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OPPOSITION TO MOTION FOR SUMMARY JUDGMENT

3. 1
MEMORANDUM OF POINTS AND AUTHORITIES
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3 I.
4 STATEMENT OF FACTS
5 This case arises out of ________________________________________________.
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Put down a brief description of the case, such as breach of contract action, with cross-
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complaint, etc.
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Plaintiffs complaint alleges that________________________________________. Cross-
10 complainant denies all of the allegations of Plaintiffs’ complaint.
11 Cross-complainant filed and served a Cross-Complaint for Breach of Contract, Fraud and
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Declaratory Relief against ______________________________________.
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Cross-Defendants then filed their Motion for Summary Judgment contending that because of
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the deemed admitted requests for admission against Cross-complainant that Cross-complainant’s
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16 Cross-Complaint has no merit.
17 Cross-complainant opposes Cross-Defendants Motion on the grounds that there are triable
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issues of material fact in that ______________________________________.
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Thus there are triable issues of material fact as to who breached the contract, whether Cross-
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Defendants committed fraud against Cross-complainant, and as to whether Cross-complainant is
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22 entitled to declaratory relief. Cross-complainant thus contends that the Court should deny Cross-
23 Defendants Motion and allow all of the claims in this case to be heard on their merits, as the law
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favors.
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Cross-complainant contends that it can show credible evidence of triable issues of material
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fact exist for all three causes of action of the Cross-Complaint.
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OPPOSITION TO MOTION FOR SUMMARY JUDGMENT

4. 1
MEMORANDUM OF POINTS AND AUTHORITIES
2
3 I.
4 STATEMENT OF FACTS
5 This case arises out of ________________________________________________.
6
Put down a brief description of the case, such as breach of contract action, with cross-
7
complaint, etc.
8
9
Plaintiffs complaint alleges that________________________________________. Cross-
10 complainant denies all of the allegations of Plaintiffs’ complaint.
11 Cross-complainant filed and served a Cross-Complaint for Breach of Contract, Fraud and
12
Declaratory Relief against ______________________________________.
13
Cross-Defendants then filed their Motion for Summary Judgment contending that because of
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the deemed admitted requests for admission against Cross-complainant that Cross-complainant’s
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16 Cross-Complaint has no merit.
17 Cross-complainant opposes Cross-Defendants Motion on the grounds that there are triable
18
issues of material fact in that ______________________________________.
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Thus there are triable issues of material fact as to who breached the contract, whether Cross-
20
Defendants committed fraud against Cross-complainant, and as to whether Cross-complainant is
21
22 entitled to declaratory relief. Cross-complainant thus contends that the Court should deny Cross-
23 Defendants Motion and allow all of the claims in this case to be heard on their merits, as the law
24
favors.
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Cross-complainant contends that it can show credible evidence of triable issues of material
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fact exist for all three causes of action of the Cross-Complaint.
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OPPOSITION TO MOTION FOR SUMMARY JUDGMENT

5. 1
MEMORANDUM OF POINTS AND AUTHORITIES
2
3 I.
4 STATEMENT OF FACTS
5 This case arises out of ________________________________________________.
6
Put down a brief description of the case, such as breach of contract action, with cross-
7
complaint, etc.
8
9
Plaintiffs complaint alleges that________________________________________. Cross-
10 complainant denies all of the allegations of Plaintiffs’ complaint.
11 Cross-complainant filed and served a Cross-Complaint for Breach of Contract, Fraud and
12
Declaratory Relief against ______________________________________.
13
Cross-Defendants then filed their Motion for Summary Judgment contending that because of
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the deemed admitted requests for admission against Cross-complainant that Cross-complainant’s
15
16 Cross-Complaint has no merit.
17 Cross-complainant opposes Cross-Defendants Motion on the grounds that there are triable
18
issues of material fact in that ______________________________________.
19
Thus there are triable issues of material fact as to who breached the contract, whether Cross-
20
Defendants committed fraud against Cross-complainant, and as to whether Cross-complainant is
21
22 entitled to declaratory relief. Cross-complainant thus contends that the Court should deny Cross-
23 Defendants Motion and allow all of the claims in this case to be heard on their merits, as the law
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favors.
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Cross-complainant contends that it can show credible evidence of triable issues of material
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fact exist for all three causes of action of the Cross-Complaint.
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OPPOSITION TO MOTION FOR SUMMARY JUDGMENT

6. 1
MEMORANDUM OF POINTS AND AUTHORITIES
2
3 I.
4 STATEMENT OF FACTS
5 This case arises out of ________________________________________________.
6
Put down a brief description of the case, such as breach of contract action, with cross-
7
complaint, etc.
8
9
Plaintiffs complaint alleges that________________________________________. Cross-
10 complainant denies all of the allegations of Plaintiffs’ complaint.
11 Cross-complainant filed and served a Cross-Complaint for Breach of Contract, Fraud and
12
Declaratory Relief against ______________________________________.
13
Cross-Defendants then filed their Motion for Summary Judgment contending that because of
14
the deemed admitted requests for admission against Cross-complainant that Cross-complainant’s
15
16 Cross-Complaint has no merit.
17 Cross-complainant opposes Cross-Defendants Motion on the grounds that there are triable
18
issues of material fact in that ______________________________________.
19
Thus there are triable issues of material fact as to who breached the contract, whether Cross-
20
Defendants committed fraud against Cross-complainant, and as to whether Cross-complainant is
21
22 entitled to declaratory relief. Cross-complainant thus contends that the Court should deny Cross-
23 Defendants Motion and allow all of the claims in this case to be heard on their merits, as the law
24
favors.
25
Cross-complainant contends that it can show credible evidence of triable issues of material
26
fact exist for all three causes of action of the Cross-Complaint.
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OPPOSITION TO MOTION FOR SUMMARY JUDGMENT