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

Attorney for Defendant, __[name]___


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

_ _ _ _ _ _ _ _ _ _ _ _ _  )   No. _ _ _ _ _ _
                               Plaintiff(s))
vs.                                                        )NOTICE OF MOTION FOR ORDER
                                                                          )REQUIRING SECURITY;
_ _ _ _ _ _ _ _ _ _ _ _ _  )   __[POINTS AND AUTHORITIES;]__
                               Defendant(s))__[DECLARATION(S);]__
_________________________  )   __[PROPOSED ORDER]__

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

     PLEASE TAKE NOTICE that defendant, __[name]__, moves the
Court under __[e.g., Code of Civil Procedure section 1029.5]__
for an order requiring plaintiff, __[name]__, to furnish security
in the amount of $_ _ _ _ _ _ to ensure payment of costs to be
incurred in defense of the action. The grounds for issuance of
this order are that __[e.g., plaintiff will not suffer undue
financial hardship in filing such a written undertaking, and
there is no reasonable possibility that plaintiff has a cause of
action against this moving party]__.
     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