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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.


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12 Plaintiff, ) MOTION IN LIMINE
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13 vs. ) TRIAL DATE:
) TIME:
14 Any Defendant, and DOES 1-5 ) DEPT:
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15 Defendants. )
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address.
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24 To download and purchase a California eviction document


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collection containing over 30 sample documents including this sample
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27 motion in limine and many more at a huge discount visit:


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1 http://legaldocspro.net/california-eviction-litigation-document-package/
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Be sure to remove this notice and all other notices before
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using this document.
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TO _______________________ AND THEIR ATTORNEYS OF RECORD:

7 NOTICE IS HEREBY GIVEN that defendant __________________will in limine move the


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court and hereby does move, for an order excluding from trial all evidence submitted by plaintiff
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_________. The motion will be heard on _________ at ____.M, or as soon thereafter as the matter
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may be heard in Department __ of the Superior Court of California, County of ________ located at

12 ______________________________________________. The motion will be brought pursuant to

13 Evidence Code 353 and 400 et seq., Code of Civil Procedure 128(a)(3)(8), and all related
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decisional law and is brought on the grounds that the unlawful detainer complaint fails to disclose the
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reason why or how plaintiff supposedly complied with Civil Code 2932.5, 2924 and 2934a; and
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accordingly the complaint fails to state a claim for which relief may be granted, and thus there remain
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18 no issues of fact for which relevant evidence might be adduced at trial. More importantly, it is

19 acknowledged that banks, lenders and third party buyers have a secured interest in deed which was
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assigned and recorded as mandated by Civil Code 2932.5. In this case, plaintiff did not have the
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power of sale as mandated by Civil Code 2924 because there is no evidence that the secured interest
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of the current beneficiary has been properly acknowledged and recorded as required by California
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24 law.

25 The motion is based on the declarations of _________________ and exhibits attached thereto,
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the memorandum of points and authorities accompanying this motion, on the papers and records on
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1 file herein, and on such oral and documentary evidence as may be presented at the hearing of this
2 motion.
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Be sure to modify these paragraphs to suit your individual
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5 situation. Do NOT just use the wording here unless it definitely applies
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to your particular situation.
8 Dated________________ _______________________________________________
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ANY ATTORNEY OR PARTY

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Note that local rules may require you to serve and file this motion
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a certain number of days before the trial date. Be sure to check with
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14 the clerk in the department where the trial will be held before using this
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motion in limine.
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17 To purchase the entire 20 page document visit:


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https://legaldocspro.myshopify.com/products/sample-motion-in-limine-
20
for-eviction-after-foreclosure-in-california
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