Motion To Show Cause: Fill & Download for Free

In California, there’s too many to name all. Some are:Demurrer (to test sufficiency of pleadings)Motion for leave to amendMotion to strike (to eliminate improper allegations)Motion for change of venue/inconvenient forumMotion to quash service of process for lack of personal jurisdictionPlea in abatementMotion for summary judgmentMotion for temporary restraining order/preliminary injunctionMotion for writ of attachmentMotion for summary judgment/summary adjudicationMotion for continuanceMotion to compel discovery/sanctionsMotion to expunge lis pendensMotion to disqualify judge/counselMotion for relief from defaultMotions in limine, primarily regarding evidentiary issuesMotion to suppress evidenceMotion to compel settlementMotion for nonsuitMotion for directed verdictMotion for mistrialMotion for new trialMotion for reconsiderationMotion for judgment notwithstanding the verdictMotion for stay of judgmentMotion/application for attorney’s feesApplication for order to show cause re contemptThere’s lots more.

You might be able to file a lawsuit for defamation without proof, but it won’t’ last long and would be dismissed upon a proper motion to show cause.

Mortgage foreclosure, representing the plaintiff. The night before the auction, I assembled a special file, because the defendant was a serial bankruptcy-filer. On his go-around preceding the foreclosure, the Bankruptcy Court decreed that as a sanction for his repeated bogus filings, there would be no automatic stay in the future; he would need to get an order of the Bankruptcy Court imposing a stay. Armed with certified copies of the sanction order, I arrived at the courthouse. The referee announced that we were stayed and handed me a copy of the Bankruptcy Petition that had been filed at 9:00 that morning. I handed the referee a copy of the Bankruptcy Court sanction order and a copy of a Court of Appeals decision that he, as referee, was immune from suit. So the referee asked what I wanted to do and I said I wanted him to proceed with the sale. Before the auction, I announced to the people who were assembled to bid what was going on. This was a property on the upper East Side of Manhattan, 20,000 squaqre feet, and the mortgage lien was “only” $4 million. There were more than fifty vultures ready to bid. My client was the tenant who had leased the property from the serial filer and who moved into the mansion a week before the lis pendens was filed. He really really wanted to buy. I really really wanted to do the foreclosure sale. Nobody but the plaintiff put in a bid. One week later, I get served with an order to show cause out of the Bankruptcy Court on a motion to punish for contempt because, it was said, I had violated the automatic stay in bankruptcy. The fool also cited the referee. It took six months and half a dozen hearings, but in the end, Judge Blackshear dismissed the motion. On the record, the Judge said, “Mr. Connolly, you play VERY high-stakes poker. Remind me never to call your bluff: you have ice water instead of blood in your veins.” Memorable indeed.