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.

)
12 Plaintiff, ) OPPOSITION TO MOTION FOR JUDGMENT
) NOTWITHSTANDING THE VERDICT;
13 vs. ) MEMORANDUM OF POINTS AND AUTHORITIES
)
14 Any Defendant, and DOES 1-5 )
)
15 Defendants. )
)
16 )
)
17 )

18
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TO THE COURT, ALL INTERESTED PARTIES AND THEIR ATTORNEYS OF RECORD:
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 1 ______________, herein submits its opposition to the motion for judgment not withstanding
2 the verdict filed by _____ on the grounds that the motion is without merit as the verdict is supported
3
by substantial evidence.
4
The Opposition shall be based on this opposition, the attached Memorandum of Points and
5

6
Authorities, on the complete files and records of this action, and on such other oral and/or

7 documentary evidence as may be presented at the hearing on the Motion.

8
Be sure to modify these paragraphs to suit your individual
9

10 situation. Do NOT just use the wording here unless it definitely applies
11
to your particular situation.
12

13 YOU MUST SERVE AND FILE THIS MEMORANDUM ON

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15
ALL PARTIES TO THE ACTION WITHIN 10 CALENDAR DAYS
16
AFTER BEING SERVED WITH THE MOTION FOR JUDGMENT
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18 NOTWITHSTANDING THE VERDICT UNLESS YOU OBTAIN A

19
STIPULATION OR COURT ORDER TO EXTEND THE TIME. SEE
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21 CODE OF CIVIL PROCEDURE 659a.

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23

24 Dated________________ _______________________________________________
ANY ATTORNEY OR PARTY
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26
MEMORANDUM OF POINTS AND AUTHORITIES
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I.
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 1 INTRODUCTION
2 DESCRIBE THE CASE AND PROVIDE SOME RELEVANT INFORMATION SUCH
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AS TYPE OF CASE, DATE(S) OF TRIAL, DATE AND DETAILS OF JUDGMENT, ETC.
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LIST HERE NAME OF PARTY FILING MOTION filed a motion for judgment
5

6
notwithstanding the verdict (JNOV).

7 LIST YOUR NAME HERE opposes the motion for JNOV on the grounds that substantial

8 evidence supports the jurys verdict in that LIST HERE THE SPECIFIC REASONS WHY THE
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OUR MOTION FOR JUDGMENT NOTWITHSTANDING THE VERDICT SHOULD BE
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DENIED AS THERE IS SUBSTANTIAL EVIDENCE TO SUPPORT THE JURYS VERDICT.
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STATE IN DETAIL ALL FACTS THAT SUPPORT YOUR CONTENTION THAT THERE IS
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13 EVIDENCE TO SUPPORT THE JURYS VERDICT.

14
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18 opposition-to-motion-for-judgment-notwithstanding-the-
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verdict-in-california
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