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, ) OPPOSITION TO MOTION TO AMEND
) JUDGMENT TO JUDGMENT DEBTOR ON
13 vs. ) ALTER EGO LIABILITY; MEMORANDUM OF
) POINTS AND AUTHORITIES; DECLARATION OF
14 Any Defendants, and DOES 1-5, inclusive, ) __________, EXHIBITS
)
15 Defendants. ) DATE:
) TIME:
16 ) DEPT:
)
17 )
)
18 )

19
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OPPOSITION TO MOTION TO AMEND JUDGMENT TO ADD JUDGMENT DEBTOR
 1 Be sure to remove this notice and all other notices before using
2

3
this document.
4 _____________________________________ herein submits its Opposition to Plaintiffs
5
motion to amend the Judgment entered on ______ to add _____________ as a judgment debtor based
6
on alter ego liability on the grounds that:
7

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1. The motion to amend is not supported by any credible and substantial evidence that

9 would support a finding that ____________ controlled the litigation, conducted discovery or

10 appeared at trial in that the Judgment entered on ________ was obtained by default.
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2. The motion to amend is not supported by any credible and substantial evidence that
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would support a finding of alter ego liability in that LIST HERE THE FACTS SUPPORTING
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YOUR CONTENTION THAT ALTER EGO LIABILITY HAS NOT BEEN SHOWN SUCH AS
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15 NO UNITY OF INTEREST AND OWNERSHIP, NO EVIDENCE OF COMMINGLING,

16 MISREPRESENTATION, OR DIVERSION OF CORPORATE ASSETS, ETC.

17
3. The motion to amend is not timely in that the Judgment was entered on ______, and
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the motion to amend was served on ________ which is a period of ___ years since the entry of
19
Judgment.
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21 The Opposition shall be based on this Opposition, the attached Memorandum of Points and

22 Authorities, the declaration of __________ and Exhibits attached thereto, on the complete files and
23
records of this action, and on such other oral and/or documentary evidence as may be presented at the
24
hearing on the Motion.
25

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27 Dated________________ _______________________________________________
ANY ATTORNEY OR PARTY
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OPPOSITION TO MOTION TO AMEND JUDGMENT TO ADD JUDGMENT DEBTOR
 1

2
Be sure to modify these paragraphs to suit your individual
3
situation. Do NOT just use the wording here unless it definitely applies
4

5 to your particular situation. Remember that YOUR OPPOSITION

6
MUST BE SERVED AND FILED AT LEAST NINE (9) COURT DAYS
7

8 BEFORE THE HEARING. Court days means Monday through

9

10
Friday, except for Court holidays. You should serve your opposition by
11
personal delivery or overnight mail. See Code of Civil Procedure
12

13 Section 1005 for more details.

14
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18 opposition-to-motion-to-amend-judgment-to-add-alter-ego-in-
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20 california
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OPPOSITION TO MOTION TO AMEND JUDGMENT TO ADD JUDGMENT DEBTOR