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Include the following notice if a minor is named in the caption or if the motion contains other unredacted sensitive data. See § 6 of the Introduction in volume 1 of this manual concerning protection of sensitive data in filed documents. |
NOTICE: THIS DOCUMENT
CONTAINS SENSITIVE DATA
[Caption. See § 3 of the Introduction in volume 1 of this manual.]
Motion to Modify Discovery Control Plan
This Motion to Modify Discovery Control Plan is filed by [name of movant], [party designation], who shows in support:
1.Additional discovery is needed: [specify nature and extent of additional discovery].
2.The additional discovery pertains to new, amended, or supplemental pleadings or to new information disclosed in discovery response or in an amended or supplemental response. The pleadings or responses were made after the deadline for completion of discovery or so nearly before the deadline that [name of movant] does not have an adequate opportunity to conduct discovery related to the new matters. [Name of movant] would be unfairly prejudiced without the additional discovery.
3.The matters for which additional discovery is requested have changed materially since the discovery cutoff date, and the trial date has been set more than three months after the discovery period ends.
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Include other discovery matters as applicable. |
[Name of movant] requests that the Court modify the discovery control plan governing the case.
[Name]
Attorney for [name of movant]
State Bar No.:
[Email address]
[Address]
[Telephone]
[Fax]
Certificate of Conference
I certify that a reasonable effort has been made to resolve the discovery dispute without the necessity of court intervention and has failed.
[Name]
Attorney for [name of movant]
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For certificate of service, see form 21-11. |