__[Attorney name]__
__[Address]__
__[Telephone number]__

Attorney for __[e.g., Defendant]__, __[name]__


               _ _ _ _ _ _ Court, County of _ _ _ _ _ _
                      __[_ _ _ _ _ _ District]__


_ _ _ _ _ _ _ _ _ _ _ _ _  )   No. _ _ _ _ _ _
                               Plaintiff(s))
vs.                                                        )NOTICE OF MOTION TO SEVER AND
                                                                     )TRY SEPARATELY __[SPECIFY
_ _ _ _ _ _ _ _ _ _ _ _ _  )   ACTIONS OR ISSUES TO BE
                               Defendant(s))SERVERED]__ __[e.g., (CCP 597)]__;
_________________________  )   __[POINTS AND AUTHORITIES;]__
                                                                                                         __[DECLARATION(S);]__
                                                __[PROPOSED ORDER]__

                                                                                                         Hearing: __[date; time]__
                                                                                                         Department: _ _ _ _ _ _
                                                                                                         __[Estimated length:_ _]__
                                                                                                         Trial Date: __[if set]__

     PLEASE TAKE NOTICE that __[e.g., defendant]__, __[name]__, moves
the Court under __[e.g., Code of Civil Procedure section 597]__ for an
order __[e.g., that the special defense of statute of limitations be
severed from and tried before all other issues]__. The grounds for
issuance of this order are __[e.g., that the statute of limitations
defense may be tried on facts that are totally different from the
facts underlying the other issues in the case]__.
     The Court is located at __[address]__.
     This motion is based on the attached documents and exhibits
including __[specify by title (or nature) and date, e.g., the
declaration of __[name]__, dated _ _ _ _]__, __[and]__ on all papers
filed and records in this action __[, and on any evidence received at
the hearing]__.


Date: _ _ _ _ _ _                                                                                  [Signature]
                                                                                                         ___________________________
                                                                                                                                            __[Typed name]__
                                                                                                         Attorney for _ _ _ _ _ _ _ _ _ _
      


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Legal Forms : Set Two