Oppose motion to vacate judgment under Rule 60(b)(1) in United States District Court

Oppose a motion to vacate judgment under Rule 60(b)(1) in United States District Court is the topic of this blog post.  the opposition to the motion should be served and filed at least seven (7) calendar days before the hearing unless a Local Rule or order of the Court states otherwise pursuant to Federal Rule of Civil Procedure 6(c)(2).

Parties served with a motion to vacate under Rule 60(b)(1) (Rule 60) should carefully review the motion and all supporting documents to determine what grounds exist for an opposition. 

Common grounds for opposition to a motion to vacate under Rule 60(b)(1) are:

The motion is untimely in that it is brought within a reasonable time as required by Rule 60 which part that,

“ (c) Timing and Effect of the Motion. (1) Timing. A motion under Rule 60(b) must be made within a reasonable time—and for reasons (1), (2), and (3) no more than a year after the entry of the judgment or order or the date of the proceeding.”

The moving party unreasonably delayed in filing the motion.

Culpable conduct by the moving party resulted in the judgment.

No meritorious defenses to the judgment or lawsuit are presented.

The opposing party would be prejudiced if the judgment were set aside.

Numerous decisions of the Circuit Courts of Appeal including but not limited to, the Ninth Circuit Court of Appeals have stated that the moving party must show good cause for the default or judgment, diligence in seeking relief and a meritorious defense otherwise the Court has the discretion to deny the motion.

In a recent decision the Ninth Circuit Court of Appeal stated that Rule 60 does not provide relief for cases of ignorance, carelessness or inexcusable neglect.   In another case the Ninth Circuit stated that even attorney negligence that would be considered malpractice does not usually warrant the granting of relief under Rule 60(b)(1), only conduct that is considered attorney misconduct.

Another Circuit Court of Appeal also stated that the ignorance or carelessness of an attorney does not warrant relief under Rule 60 and neither do deliberate litigation strategy and choices regarding evidence.

Attorneys or parties who would like to view a portion of a 10 page sample opposition to motion to vacate judgment under Rule 60(b)(1) containing brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service by mail sold by the author can use the link shown below.

Sample opposition to Rule 60(b)(1) motion to vacate judgment

The author of this blog post, Stan Burman, is an entrepreneur and freelance paralegal who has worked in California and Federal litigation since 1995 and has created over 300 sample legal documents for California and Federal litigation.

*Do you want to use this article on your website, blog or e-zine? You can, as long as you include this blurb with it: “Stan Burman is the author of over 300 sample legal documents for California and Federal litigation and is the author of a free weekly legal newsletter. You can receive 10 free gifts just for subscribing. Just visit Subscribe to FREE weekly newsletter for more information.

Follow the author on Twitter at: Twitter page for LegalDocsPro

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DISCLAIMER:

Please note that the author of this blog post, Stan Burman is NOT an attorney and as such is unable to provide any specific legal advice. The author is NOT engaged in providing any legal, financial, or other professional services, and any information contained in this blog post is NOT intended to constitute legal advice.

The materials and information contained in this blog post have been prepared by Stan Burman for informational purposes only and are not legal advice. Transmission of the information contained in this blog post is not intended to create, and receipt does not constitute, any business relationship between the author and any readers. Readers should not act upon this information without seeking professional counsel.

How to oppose a motion to vacate judgment under Rule 60(b)(2) in United States District Court

How to oppose a motion to vacate judgment under Rule 60(b)(2) in United States District Court on the grounds of newly discovered evidence is the topic of this blog post.  The opposition to the motion should be served and filed at least seven (7) calendar days before the hearing unless a Local Rule or order of the Court states otherwise pursuant to Federal Rule of Civil Procedure 6(c)(2).

Parties served with a motion to vacate under Rule 60(b)(2) (“Rule 60”) should review the motion and all supporting documents very closely to determine what grounds exist for an opposition. 

Common grounds for opposition to a motion to vacate under Rule 60(b)(2) are:

The motion is untimely in that it is brought more than one year after the entry of judgment or it is not brought within a reasonable time as required by Rule 60 which part that,

“ (c) Timing and Effect of the Motion. (1) Timing. A motion under Rule 60(b) must be made within a reasonable time—and for reasons (1), (2), and (3) no more than a year after the entry of the judgment or order or the date of the proceeding.”

The moving party unreasonably delayed in filing the motion.

The newly discovered evidence was known or could have been discovered by the moving party before the trial.

The newly discovered evidence is merely cumulative, impeaching or not material.

The newly discovered evidence would not likely produce a different result if the judgment were set aside.

Numerous decisions of the Circuit Courts of Appeal including the Ninth Circuit have stated that the moving party must show that the newly discovered evidence was discovered after the trial, that they exercised diligence to discover the evidence, the evidence is not just cumulative or impeaching evidence, the evidence is material and that the evidence would most likely produce a different result if the judgment were set aside.

Several recent decisions of the Circuit Courts of Appeal have stated that impeachment evidence that is newly discovered does not support a motion to vacate under Rule 60 in most cases.

And several Circuit Courts of Appeal have also stated that a Rule 60(b)(2) motion for relief from judgment is subject to the same standard as a motion under Rule 59 for a new trial on the grounds of newly discovered evidence

Attorneys or parties who would like to view a portion of an 11 page sample opposition to motion to vacate judgment under Rule 60(b)(2) containing brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service by mail sold by the author can use the link shown below.

Sample opposition to Rule 60(b)(2) motion to vacate judgment

The author of this blog post, Stan Burman, is an entrepreneur and freelance paralegal who has worked in California and Federal litigation since 1995 and has created over 300 sample legal documents for California and Federal litigation.

*Do you want to use this article on your website, blog or e-zine? You can, as long as you include this blurb with it: “Stan Burman is the author of over 300 sample legal documents for California and Federal litigation and is the author of a free weekly legal newsletter. You can receive 10 free gifts just for subscribing. Just visit Subscribe to FREE weekly newsletter for more information.

Follow the author on Twitter at: Twitter page for LegalDocsPro

You can view sample legal document packages for sale by visiting: Sample legal document packages for sale

DISCLAIMER:

Please note that the author of this blog post, Stan Burman is NOT an attorney and as such is unable to provide any specific legal advice. The author is NOT engaged in providing any legal, financial, or other professional services, and any information contained in this blog post is NOT intended to constitute legal advice.

The materials and information contained in this blog post have been prepared by Stan Burman for informational purposes only and are not legal advice. Transmission of the information contained in this blog post is not intended to create, and receipt does not constitute, any business relationship between the author and any readers. Readers should not act upon this information without seeking professional counsel.

 

 

Settlement offer under Federal Rule of Evidence 408 in United States District Court

A settlement offer under Federal Rule of Evidence 408 in United States District Court is the topic of this blog post.  Rule 408 generally forbids evidence of any settlement offers or any conducts or statements made during settlement negotiations.

Rule 408 was first introduced in 1974. It replaced the original rules of evidence which represented a huge stumbling block to any meaningful settlement negotiations as under the common law any statements made during such settlement negotiations were admissible and therefore fair game for use at trial or in summary judgment motions.  Not surprisingly this threat had a very chilling effect that prevented most if not all litigants from engaging in any discussions regarding a possible settlement.  Rule 408 changed the common law rule as it forbids the admission into evidence of statements made during settlement negotiations “when offered to prove liability for, invalidity of or amount of a claim that was disputed as to validity or amount, or to impeach through a prior inconsistent statement or contradiction.”

Rule 408 was adopted to facilitate the resolution of disputes without the expense and uncertainty of protracted litigation. Many State courts around the nation have adopted their own version of Rule 408, either through formal rules or through case law. For the State of California has adopted Evidence Code sections 1152 and 1154 which serve a similar purpose.

Rule 408 states that,

“(a) Prohibited Uses. Evidence of the following is not admissible — on behalf of any party — either to prove or disprove the validity or amount of a disputed claim or to impeach by a prior inconsistent statement or a contradiction:

(1) furnishing, promising, or offering — or accepting, promising to accept, or offering to accept — a valuable consideration in compromising or attempting to compromise the claim; and

(2) conduct or a statement made during compromise negotiations about the claim — except when offered in a criminal case and when the negotiations related to a claim by a public office in the exercise of its regulatory, investigative, or enforcement authority.

(b) Exceptions. The court may admit this evidence for another purpose, such as proving a witness’s bias or prejudice, negating a contention of undue delay, or proving an effort to obstruct a criminal investigation or prosecution.”

Rule 408 does have some exceptions. For example any previous settlement negotiations between a plaintiff and another party could be introduced by a defendant to establish for statute of limitations purposes the date that plaintiff understood the cause of his or her injuries.

Attorneys or parties who would like to view a sample settlement offer letter under Federal Rule of Evidence 408 created by the author and available for free download can use the link shown below.

Sample settlement offer under Federal Rule of Evidence 408

The author of this blog post, Stan Burman, is an entrepreneur and freelance paralegal who has worked in California and Federal litigation since 1995 and has created over 300 sample legal documents for California and Federal litigation. 

*Do you want to use this article on your website, blog or e-zine? You can, as long as you include this blurb with it: “Stan Burman is the author of over 300 sample legal documents for California and Federal litigation and is the author of a free weekly legal newsletter. You can receive 10 free gifts just for subscribing. Just visit Subscribe to FREE weekly newsletter for more information.

Follow the author on Twitter at: Twitter page for LegalDocsPro

You can view sample legal document packages for sale by visiting: Sample legal document packages for sale

DISCLAIMER:

Please note that the author of this blog post, Stan Burman is NOT an attorney and as such is unable to provide any specific legal advice. The author is NOT engaged in providing any legal, financial, or other professional services, and any information contained in this blog post is NOT intended to constitute legal advice.

The materials and information contained in this blog post have been prepared by Stan Burman for informational purposes only and are not legal advice. Transmission of the information contained in this blog post is not intended to create, and receipt does not constitute, any business relationship between the author and any readers. Readers should not act upon this information without seeking professional counsel.

 

 
 

Right to a jury trial in California

http://www.legaldocspro.com/blog/right-to-a-trial-by-jury-in-california/

Code of Civil Procedure section 1161.2 notice of unlawful detainer in California

http://www.legaldocspro.com/blog/code-of-civil-procedure-section-1161-2-notice-of-unlawful-detainer-in-california/

Opposition to Code of Civil Procedure section 663 motion in California

An opposition to a Code of Civil Procedure section 663 motion to set aside and vacate a judgment and enter another and different judgment in California is the topic of this blog post.  

Any party wishing to oppose a motion under Code of Civil Procedure section should serve and file their opposition at least nine (9) court days before the hearing and should be served by personal delivery or overnight mail pursuant to Code of Civil Procedure section 1005 unless the court has ordered otherwise.

Any party served with a motion to vacate and enter a different judgment should review closely the motion and all supporting declaration to determine what grounds exist for an opposition.  The first possible ground for opposition is that the motion is not timely filed as in most cases the motion must be filed within 15 days after the party is served with a notice of entry of judgment, either by the clerk of the court, or any other party.  For more information parties should review Code of Civil Procedure section 663a.

Other possible grounds for opposition would be that the moving party has not met their burden of showing sufficient facts or evidence to support either of the two grounds listed in Code of Civil Procedure section 663 which states that, 

“A judgment or decree, when based upon a decision by the court, or the special verdict of a jury, may, upon motion of the party aggrieved, be set aside and vacated by the same court, and another and different judgment entered, for either of the following causes, materially affecting the substantial rights of the party and entitling the party to a different judgment:

1. Incorrect or erroneous legal basis for the decision, not consistent with or not supported by the facts; and in such case when the judgment is set aside, the statement of decision shall be amended and corrected.

2. A judgment or decree not consistent with or not supported by the special verdict.”

The opposition should include enough supporting facts and evidence to support the opposition such as the fact that a judgment entered after a court trial is consistent with the legal conclusion to be drawn from the facts as found by the court and that the motion may not challenge the factual bases for the decision of the court, and for a judgment entered after a jury trial that the judgment is consistent with the special verdict of the jury.

A California Court of Appeal ruled in a case from over 75 years ago that so long as the judgment rendered is the correct legal conclusion to be drawn from the facts found by the court, any motion to set aside and vacate a judgment and enter another and different judgment should be denied.

Another California Court of Appeal in a recent case ruled that a motion to set aside and vacate a judgment and enter another and different judgment cannot be used to challenge the factual bases for the decision of the court.

Attorneys or parties in California who would like to view a portion of a 10 page sample opposition to a motion to set aside and vacate a judgment and enter another and different judgment containing brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service sold by the author can use the link shown below. 

Sample opposition to motion to vacate judgment in California

The author of this blog post, Stan Burman, is an entrepreneur and freelance paralegal who has worked in California and Federal litigation since 1995 and has created over 300 sample legal documents for California and Federal litigation.

*Do you want to use this article on your website, blog or e-zine? You can, as long as you include this blurb with it: “Stan Burman is the author of over 300 sample legal documents for California and Federal litigation and is the author of a free weekly legal newsletter. You can receive 10 free gifts just for subscribing. Just visit Subscribe to FREE weekly newsletter for more information.

Follow the author on Twitter at: Twitter page for LegalDocsPro

You can view sample legal document packages for sale by visiting: Sample legal document packages for sale

DISCLAIMER:

Please note that the author of this blog post, Stan Burman is NOT an attorney and as such is unable to provide any specific legal advice. The author is NOT engaged in providing any legal, financial, or other professional services, and any information contained in this blog post is NOT intended to constitute legal advice.

The materials and information contained in this blog post have been prepared by Stan Burman for informational purposes only and are not legal advice. Transmission of the information contained in this blog post is not intended to create, and receipt does not constitute, any business relationship between the author and any readers. Readers should not act upon this information without seeking professional counsel.

 

Code of Civil Procedure section 397(c) motion for change of venue in California

A Code of Civil Procedure section 397(c) motion for change of venue in California is the topic of this blog post. A motion under Code of Civil Procedure section 397(c) is filed on the grounds that both the convenience of witnesses and the ends of justice would be promoted by the change of venue. 

Code of Civil Procedure § 397 states in pertinent part that “The court may, on motion, change the place of trial in the following cases:

(c) When the convenience of witnesses and the ends of justice would be promoted by the change.”

A motion filed under Section 397(c) is a very powerful motion if filed in the correct situations as the court has the power to modify the choices of the parties as to where the action should be tried. Plaintiff may have the right to file wherever venue is considered proper under the relevant venue statutes but the court still has the discretion to order a change of venue if trying the case locally would be seriously inconvenient to the witnesses and defeat the ends of justice.  A motion under section 397(c) can also be used against a defendant who has successfully changed the original venue of the case, in such cases the transferee court has the power to change venue to the original venue or another county altogether so long as the convenience of witnesses and the ends of justice would be promoted by the change of venue. 

Any motion for change of venue in California filed under Code of Civil Procedure section 397(c) should not be filed until after an answer to the complaint has been filed so that the court can determine exactly what issues are raised by the complaint and the answer.  The term witnesses refers only to non-party witnesses unless a party is so extremely ill or feeble so that travel to a distant county would endanger his or her health. See Simonian v. Simonian (1950) 97 Cal.App.2d 68, 69.

Note that the motion should be filed within a reasonable period of time after the answer has been filed as the California Supreme Court has stated that what constitutes a "reasonable" time for filing a motion for change of venue under Code of Civil Procedure § 397 rests largely in the trial court's discretion. See Cooney v. Cooney (1944) 25 Cal.2d 202, 208.

A California Court of Appeal has stated that the convenience of witnesses can be shown by the fact that the residence of all of the witnesses is in the same county to which the transfer is requested.  That same Court of Appeal also stated that the trial court in making a determination that the ends of justice will be promoted by a change of venue can rely not only on the direct facts set forth in the affidavits but can also rely on any reasonable and relevant inferences that arise therefrom.

The scope of a motion for change of venue under section 397 is broad as Section 397 applies to any action or proceeding within its terms . . . even actions under statutes (e.g., FEHA) giving plaintiff the broadest possible choice of venue. See Richfield Hotel Management, Inc. v. Sup.Ct. (Riddell) (1994) 22 Cal.App.4th 222, 225.

Attorneys or parties in California who would like to view a portion of a sample 10 page motion for change of venue under CCP section 397(c) containing brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service by mail sold by the author can use the link shown below.

Sample motion for change of venue under CCP section 397(c) in California



The author of this blog post, Stan Burman, is an entrepreneur and freelance paralegal who has worked in California and Federal litigation since 1995 and has created over 300 sample legal documents for California and Federal litigation. 

If you are in need of assistance with any California or Federal litigation matters, Mr. Burman is available on a freelance basis. Mr. Burman may be contacted by e-mail at DivParalgl@yahoo.com for more information. He accepts payments through PayPal which means that you can pay using most credit or debit cards.

*Do you want to use this article on your website, blog or e-zine? You can, as long as you include this blurb with it: “Stan Burman is the author of over 300 sample legal documents for California and Federal litigation and is the author of a free weekly legal newsletter. You can receive 10 free gifts just for subscribing. Just visit Subscribe to FREE weekly newsletter for more information.

Follow the author on Twitter at: Twitter page for LegalDocsPro

You can view sample legal document packages for sale by visiting: Sample legal document packages for sale

DISCLAIMER:

Please note that the author of this blog post, Stan Burman is NOT an attorney and as such is unable to provide any specific legal advice. The author is NOT engaged in providing any legal, financial, or other professional services, and any information contained in this blog post is NOT intended to constitute legal advice.

The materials and information contained in this blog post have been prepared by Stan Burman for informational purposes only and are not legal advice. Transmission of the information contained in this blog post is not intended to create, and receipt does not constitute, any business relationship between the author and any readers. Readers should not act upon this information without seeking professional counsel.

 

Continuance of California trial date

http://www.legaldocspro.com/blog/continuing-a-trial-date-in-california/

Extension of time to plead in California

How to obtain an extension of time to plead in California is the topic of this blog post. An extension of time to plead in California may be granted to respond to a complaint, cross-complaint as well as certain other pleadings. Code of Civil Procedure section 1054(a) authorizes a judge upon a showing of good cause to grant an extension of tine not exceeding 30 days to respond to a complaint, cross-complaint or other pleading.

The request for an extension of time may be made by ex-parte application if necessary.

Code of Civil Procedure § 1054(a) states that, “When an act to be done, as provided in this code, relates to the pleadings in the action, or the preparation of bills of exceptions, or of amendments thereto, or to the service of notices other than of appeal and of intention to move for a new trial, the time allowed therefor, unless otherwise expressly provided, may be extended, upon good cause shown, by the judge of the court in which the action is pending, or by the judge who presided at the trial of the action; but the extension so allowed shall not exceed 30 days, without the consent of the adverse party.”

The decision as to whether or not an extension of time is granted is left to the discretion of the

judge hearing the motion.  Good cause is generally shown by a sufficient showing that the extension is needed to obtain the filing fees for the response or to obtain the funds to retain an attorney, an attorney has been contacted but they need more time to review the case or a family emergency requires the defendant to travel out of town.  Any declarations submitted in support of the request should contain sufficient facts and evidence that support a strong showing that circumstances beyond the control of the defendant or requesting party have necessitated the request for an extension of time to respond.

Any request for an extension of time to respond should clearly state whether or not any previous extensions of time to respond by court order or stipulation have been granted.

Attorneys or parties wishing to request an extension of time to respond should first contact the plaintiff or opposing party or their attorney and request that they stipulate to an extension of time to respond. If the request is denied that fact should be mentioned in the supporting declaration.

Attorneys or parties in California who would like to view a portion of an 11 page sample ex-parte application for extension of time to respond to a complaint including brief instructions, a memorandum of points and authorities with citations to statutory authority, sample declaration and declaration regarding ex-parte notice and proposed order sold by the author can use the link shown below.

Sample ex-parte application for extension of time to plead for California

 

The author of this blog post, Stan Burman, is an entrepreneur and freelance paralegal who has worked in California and Federal litigation since 1995 and has created over 300 sample legal documents for California and Federal litigation.

*Do you want to use this article on your website, blog or e-zine? You can, as long as you include this blurb with it: “Stan Burman is the author of over 300 sample legal documents for California and Federal litigation and is the author of a free weekly legal newsletter. You can receive 10 free gifts just for subscribing. Just visit http://freeweeklylegalnewsletter.gr8.com/ for more information.

Follow the author on Twitter at: https://twitter.com/LegalDocsPro

You can view sample legal document packages for sale by visiting: http://www.legaldocspro.com/downloads.aspx

DISCLAIMER:

Please note that the author of this blog post, Stan Burman is NOT an attorney and as such is unable to provide any specific legal advice. The author is NOT engaged in providing any legal, financial, or other professional services, and any information contained in this blog post is NOT intended to constitute legal advice.

The materials and information contained in this blog post have been prepared by Stan Burman for informational purposes only and are not legal advice. Transmission of the information contained in this blog post is not intended to create, and receipt does not constitute, any business relationship between the author and any readers. Readers should not act upon this information without seeking professional counsel.

California motion to strike complaint

A California motion to strike a complaint or portions of a complaint is the topic of this blog post.   

A motion to strike may request that an entire complaint or certain specified portions be stricken.

In the State of California a motion to strike may be filed to strike any irrelevant matter inserted in any pleading, and to strike any pleading or part thereof not drawn in conformity with the laws of this state. See Code of Civil Procedure § 436.

A California Court of Appeal has ruled that if a claim of right appears on the face of a complaint which is legally invalid that the complaint is subject to a motion to strike.

For instance if a complaint requests attorney fees, yet the complaint fails to allege a contractual or statutory basis which entitles the plaintiff to recover attorney fees then the request for attorneys fees is subject to a motion to strike. And if the complaint requests any other relief to which plaintiff is not entitled to, that portion of the complaint is also subject to a motion to strike.

As with a demurrer no extrinsic evidence can be considered in ruling on a motion to strike unless the extrinsic evidence is subject to judicial notice.

A defendant cannot base a motion to strike on affidavits, declarations, or matters outside the four corners of the pleading containing extrinsic evidence that allegations in the complaint are false or a sham; such challenges only lie on the face of the complaint.

Although older cases recognized that a complaint cannot generally allege entitlement to punitive damages this is no longer the case in California.

The issue of whether or not to file a motion to strike should only be made after legal research on whether plaintiff is requesting relief to which they are not entitled, or if the complaint contains irrelevant matter. If so, then a motion to strike should be filed.

Attorneys or parties in California who wish to view a portion of a sample motion to strike to a complaint containing a memorandum of points and authorities with citations to case law and statutory authority and proof of service by mail sold by the author can use the link shown below.

Sample motion to strike for California

The author of this blog post, Stan Burman, is an entrepreneur and freelance paralegal who has worked in California and Federal litigation since 1995 and has created over 300 sample legal documents for California and Federal litigation.

*Do you want to use this article on your website, blog or e-zine? You can, as long as you include this blurb with it: “Stan Burman is the author of over 300 sample legal documents for California and Federal litigation and is the author of a free weekly legal newsletter. You can receive 10 free gifts just for subscribing. Just visit http://freeweeklylegalnewsletter.gr8.com/ for more information.

Follow the author on Twitter at: https://twitter.com/LegalDocsPro

You can view sample legal document packages for sale by visiting: http://www.legaldocspro.com/downloads.aspx

DISCLAIMER:

Please note that the author of this blog post, Stan Burman is NOT an attorney and as such is unable to provide any specific legal advice. The author is NOT engaged in providing any legal, financial, or other professional services, and any information contained in this blog post is NOT intended to constitute legal advice.

The materials and information contained in this blog post have been prepared by Stan Burman for informational purposes only and are not legal advice. Transmission of the information contained in this blog post is not intended to create, and receipt does not constitute, any business relationship between the author and any readers. Readers should not act upon this information without seeking professional counsel.

File a motion to strike an unlawful detainer (eviction) complaint in the State of California

http://www.legaldocspro.com/blog/motion-to-strike-an-unlawful-detainer-complaint-in-california/

Experienced virtual paralegal available for hire

Virtual paralegal who has worked in California and Federal litigation since 1995 available for short-term projects involving off-site work for licensed attorneys and law firms in California. Extensive experience in reviewing pleadings and drafting appropriate responses based on legal research. Capable of working with little or no supervision. Excellent references available. Payments are accepted through PayPal. 

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