Sample Motion for Judgment on the Pleadings for Plaintiff in California

Sample Motion for Judgment on the Pleadings for Plaintiff in California. This sample motion for judgment on the pleadings for California is for use by a plaintiff who contends that the answer filed by a defendant fails to state enough facts to constitute a defense to the complaint.  This motion serves the same purpose as a general demurrer to an answer but it can be filed objecting to the answer of a defendant even after the time to file a demurrer to the answer has expired. The sample motion is 36 pages, has been revised and updated in 2019 and includes, Brief instructions, Table of contents and table of authorities, Memorandum of points and authorities with citations to case law and statutory authority, Declaration regarding compliance with the meet and confer requirements of Code of Civil Procedure § 439(a), and Proof of service. The author is an entrepreneur and retired litigation paralegal that worked in California and Federal litigation from January 1995 through September 2017