Motions (Court Request Filings)

Motions are essential tools that influence how a case progresses. Clear, organized filings help ensure your requests are presented professionally and on time. Our office provides structured document preparation based on the information and instructions you provide.

In many courts, hearing dates for noticed motions are typically set several weeks or even months out, depending on the court’s calendar and availability. If your situation requires faster attention and there is not enough time for a standard noticed motion to be heard, you may consider whether an Ex Parte application is appropriate for your circumstances. We can prepare the required documents based on your timeline and the materials you provide.

Below is an expanded list of popular motions, now arranged in alphabetical order for easy reference.

Popular Motions (Alphabetical Order)

• Motion for Continuance: Requests a new date for an upcoming hearing or trial.
• Motion for Injunction: Requests immediate Court orders to stop harmful actions or prevent further damage.
• Motion for Leave to Amend: Seeks permission to file an amended complaint or answer.
• Motion for Protective Order: Seeks to limit or prevent certain discovery activities.
• Motion for Reconsideration: Requests reevaluation of a Court decision based on new information.
• Motion for Sanctions: Requests penalties for improper conduct or discovery violations.
• Motion for Summary Judgment / Summary Adjudication: Seeks resolution when facts are undisputed.
• Motion in Limine: Filed before trial to exclude or limit specific evidence.
• Motion to Bifurcate: Requests separating issues (e.g., liability and damages) into separate phases.
• Motion to Compel: Requests enforcement of overdue or incomplete discovery responses.
• Motion to Compel Compliance with Court Order: Requests enforcement of a prior Court order.
• Motion to Compel Further Responses: Requests more complete or adequate discovery responses.
• Motion to Dismiss / Demurrer: Requests review of whether a pleading meets procedural requirements.
• Motion to Quash Service: Challenges the method or validity of service of summons.
• Motion to Set Aside Default: Requests reversal of a default or default judgment.
• Motion to Strike: Requests removal of improper or unnecessary allegations from a pleading.

Filing Considerations

Separate Motion Requirement: Many motions are filed individually due to different timelines, notice rules, and supporting materials. Independent filings help ensure clarity for both scheduling and review.

Combining Multiple Issues in One Motion: Some motions allow multiple issues within the same filing, particularly where the issues share the same procedural basis—such as certain discovery or summary adjudication motions.

Discovery Grouping: When discovery disputes relate to the same set of requests, grouping may be appropriate. Different discovery tools, however, often require separate filings.

Pre-Trial Motions: Motions in Limine are commonly filed in sets before trial, each addressing a distinct evidentiary issue.

Practical Filing Principle: The general approach is to file motions separately unless the nature of the issues clearly supports a combined format.

Because motions involve deadlines and formal formatting requirements, early preparation is recommended to ensure your filings are complete and ready for submission.