Sample Opposition to Motion for Judgment on the Pleadings for Defendant in California

Sample Opposition to Motion for Judgment on the Pleadings for Defendant in California. This sample opposition to a motion for judgment on the pleadings for a Defendant in California is used to oppose a motion for judgment on the pleadings on the grounds that (1) the complaint of Plaintiff fails to state facts sufficient to constitute a cause of action and (2) that the answer raises both material issues and states facts sufficient to constitute a defense to the complaint. The opposition also requests leave to amend in the event that the Court is inclined to grant the motion for judgment on the pleadings. The opposition has been revised and updated in 2019, is 14 pages, and includes, Brief instructions, Memorandum of points and authorities with citations to case law and statutory authority, 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 and has created over 30