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 In re the marriage of: ) Case No.

)
12 Petitioner: _________________________ ) MEMORANDUM OF POINTS AND AUTHORITIES
) IN SUPPORT OF MOTION FOR
13 and ) DAMAGES AND SANCTIONS FOR BREACH OF
) FIDUCIARY DUTY UNDER FAMILY CODE
14 Respondent:____________________________ ) SECTIONS 721 AND 1101 AND REQUEST FOR
) SANCTIONS PURSUANT TO FAMILY CODE
15 ) SECTION 271; DECLARATION OF ________;
) EXHIBITS
16 )
) DATE:
17 ) TIME:
) DEPT:
18

19
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POINTS AND AUTHORITIES-MOTION FOR DAMAGES AND SANCTIONS
 1 http://legaldocspro.net/california-eviction-litigation-document-package/
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Be sure to remove this notice and all other notices before using
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this document.
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TO THE COURT, ALL INTERESTED PARTIES AND THEIR ATTORNEYS OF RECORD:

7 NAME AND CAPACITY OF MOVING PARTY herein submits their Memorandum of

8 Points and Authorities in support of their motion for damages and sanctions for breach of fiduciary
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duty under Family Code 721, 1101 on the grounds that LIST HERE THE GROUNDS SUCH
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AS THE OTHER PARTY BREACHED THEIR FIDUCIARY DUTY AND CONCEALED
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COMMUNITY PROPERTY AND DID SO IN AN ATTEMPT TO DEFRAUD YOU, ETC. and
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13 for as sanctions pursuant to Family Code 271, 2100 in the amount of $LIST AMOUNT and

14 attorneys fees in the amount of $LIST AMOUNT for a total award of sanctions and attorneys fees
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in the amount of $LIST AMOUNT against NAME OF OTHER PARTY on the grounds that LIST
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HERE THE GROUNDS SUCH AS THE OTHER PARTY AND/OR THEIR COUNSEL
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CONCEALED COMMUNITY PROPERTY AND DID SO IN AN ATTEMPT TO DEFRAUD
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19 YOU, ETC. AND BREACHED THEIR FIDUCIARY DUTY as more fully set forth in the

20 declaration(s) of MOVING PARTY and exhibits attached thereto, concurrently filed and served
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herewith and incorporated herein by reference.
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The motion will be based on the notice of motion or request for order and the memorandum of
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points and authorities concurrently served and filed herewith, on the declaration of MOVING
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25 PARTY and Exhibits attached thereto concurrently served and filed herewith, on the papers and

26 records on file herein, and on such oral and documentary evidence as may be presented at the hearing
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of the motion
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POINTS AND AUTHORITIES-MOTION FOR DAMAGES AND SANCTIONS
 1 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. Do NOT ask for attorneys fees if you are
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6 representing yourself unless you have actually incurred attorneys fees.

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family-code-section-1101-damages-and-sanctions
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POINTS AND AUTHORITIES-MOTION FOR DAMAGES AND SANCTIONS