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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 _________________

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11 Any Plaintiff, ) Case No.


)
12 Plaintiff, ) NOTICE OF MOTION AND MOTION FOR
) JUDGMENT NOTWITHSTANDING THE
13 vs. ) VERDICT; MEMORANDUM OF POINTS AND
) AUTHORITIES
14 Any Defendant, and DOES 1-5 )
)
15 Defendants. )
)
16 )
)
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address. Be sure to remove this notice and all other notices before
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TO THE COURT, ALL INTERESTED PARTIES AND THEIR ATTORNEYS OF RECORD:
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1 PLEASE TAKE NOTICE that on _______________ at _________M., or as soon after that as
2 the matter can be heard, Department ________ of the above-entitled court located at
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______________________________, __________ will and does move this Court for an order for
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judgment in their favor, notwithstanding the verdict. The motion will be made on the following
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grounds:

7 1. After viewing the evidence in the light most favorable to LIST NAME OF PARTY

8 SECURING THE VERDICT, there is no substantial evidence to support the jury's verdict in that
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party's favor and a directed verdict for LIST YOUR NAME HERE should have been granted had a
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previous motion for directed verdict been made.
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ONLY USE NUMBER 2 BELOW IF YOU PREVIOUSLY MOVED FOR A DIRECTED
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13 VERDICT.

14 2. On each and all of the grounds on which the motion for a directed verdict was made.
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The motion will be based on this notice of motion and the memorandum of points and
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authorities served and filed herewith, on the papers and records on file herein, and on such oral and
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documentary evidence as may be presented at the hearing of the motion
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19 Be sure to modify these paragraphs to suit your individual


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situation. Do NOT just use the wording here unless it definitely applies
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to your particular situation.
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24 Note that you MUST file and serve this notice of motion and
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memorandum of points and authorities within 15 days of the date of
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27 mailing notice of entry of judgment by the clerk of the court, or service


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1 upon you by any party of written notice of entry of judgment, or within
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180 days after the entry of judgment, whichever is earliest. You MUST
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also serve all adverse parties. This time period cannot be extended by
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6 any court or any stipulation. See Code of Civil Procedure sections 629
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and 659.
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10 Dated________________ _______________________________________________
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ANY ATTORNEY OR PARTY

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15 judgment-notwithstanding-the-verdict-for-california
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