This document is a notice of motion and motion to amend a judgment to add a judgment debtor on an alter ego theory. It provides notice that on a specified date and time, in a specified court department, the plaintiff will move to amend a judgment entered on a particular date to add a specified party as a judgment debtor. It argues that alter ego liability is appropriate because there is such a unity of interest and ownership between the corporation and the party sought to be added as a judgment debtor that their separate personalities do not exist, and failing to add the party would sanction fraud or promote injustice. It states the motion is based on this notice, an accompanying memorandum of points and authorities, a supporting declaration and exhibits.

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Any Attorney or Party
Any Street
Any Town, CA 55555
714-555-5555
Any Attorney or Party
Superior Court of the State of California
For the County of _________________
Any Plaintiff,
Plaintiff,
vs.
Any Defendant, and DOES 1-5
Defendants.
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Case No.
NOTICE OF MOTION AND MOTION TO AMEND
JUDGMENT TO ADD ____________ JUDGMENT
DEBTOR ON ALTER EGO THEORY UNDER
CODE OF CIVIL PROCEDURE SECTION 187;
MEMORANDUM OF POINTS AND
AUTHORITIES; DECLARATION OF
_______________; EXHIBITS
DATE:
TIME:
DEPT:
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NOTICE OF MOTION AND MOTION TO AMEND JUDGMENT TO ADD JUDGMENT DEBTOR

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Be sure to remove this notice and all other notices before
using this document.
TO THE ABOVE-ENTITLED COURT, ALL PARTIES HEREIN, AND THEIR
ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE THAT on _____________ at __________ or as soon
thereafter as the matter may be heard, in Department ________ of the above-entitled Court, located at
________________________ , pursuant to California Code of Civil Procedure Section 187,
Plaintiff _____________ will and does move this court for an order amending the judgment entered
on ______ to add LIST NAME OF PARTY TO BE ADDED AS JUDGMENT DEBTOR on the
grounds of alter ego liability in that there is such as unity of interest and ownership between the
corporation and LIST NAME OF PARTY TO BE ADDED AS JUDGMENT DEBTOR, who is
its equitable owner that the separate personalities of the corporation and the shareholder do not in
reality exist, and that failure to do would sanction fraud or promote injustice.
This motion will be based on this notice and on the memorandum of points and authorities
served and filed herewith, on the declaration of ____________ and exhibits attached thereto, on all
the papers and records of this action and on such other and further oral and/or documentary evidence
as may be presented at the hearing on this motion.
Be sure to modify these paragraphs to suit your individual
situation. Do NOT just use the wording here unless it definitely applies
to your particular situation.
Dated________________ _______________________________________________
ANY ATTORNEY OR PARTY
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NOTICE OF MOTION AND MOTION TO AMEND JUDGMENT TO ADD JUDGMENT DEBTOR

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MEMORANDUM OF POINTS AND AUTHORITIES
I.
STATEMENT OF FACTS
Plaintiff filed suit against Defendants on or about ___________ alleging: Add some brief
facts regarding the lawsuit such as breach of contract, et. See Plaintiffs complaint on file.
Judgment was entered against Defendant on _______________.
Plaintiff contends that, pursuant to California Code of Civil Procedure Section 187,
this court should issue an order amending the judgment entered on ______ to add LIST NAME OF
PARTY TO BE ADDED AS JUDGMENT DEBTOR on the grounds of alter ego liability in that
there is such as unity of interest and ownership between the corporation and LIST NAME OF
PARTY TO BE ADDED AS JUDGMENT DEBTOR, and its equitable owner that the separate
personalities of the corporation and the shareholder do not in reality exist, and that failure to do
would sanction fraud or promote injustice in that LIST HERE THE SPECIFIC REASONS WHY
THE COURT SHOULD IMPOSE ALTER EGO LIABILITY ON THE OTHER PARTY
SUCH AS FAILURE TO OBSERVE CORPORATE FORMALITIES, COMMINGLING OF
FUNDS, ETC. See the declaration of __________ and Exhibits attached thereto, concurrently filed
and served herewith and incorporated herein by reference.
To view the sample document on which this preview is based visit:
http://www.scribd.com/doc/228431088/Sample-Motion-to-Amend-
Judgment-to-Add-Alter-Ego-as-Judgment-Debtor-in-California
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NOTICE OF MOTION AND MOTION TO AMEND JUDGMENT TO ADD JUDGMENT DEBTOR