[Firm Name]
[Firm Address]
[Firm Phone Number]
[Firm Fax]
[Firm Email]
[Attorney Name and Bar Number]
Attorney for Defendant(s)
[Trial Court System], [County]
[Plaintiff Name(s)],
Plaintiff(s),
v.
[Defendant(s)],
Defendant(s). |
Case No.
MOTION TO DISMISS FOR FAILURE TO SECURE TIMELY SERVICE
Assigned to the Hon. [Judge]
|
- Pursuant to [local civil rule], defendant [Defendant], by and through undersigned counsel, respectfully requests the Court enter an Order dismissing this action without prejudice for the reason that service of process has not been accomplished within [#] days after the filing of the Complaint, as required by [local civil rule].
- By making this Motion, defendant [Defendant] does not waive, and expressly preserves, any objections to the jurisdiction of this court, and to venue in this County.
- This Motion is supported by the accompanying Memorandum of Points and Authorities, and the [exhibits and affidavit with corresponding exhibit numbers], which are attached hereto and incorporated herein by this reference.
Dated this [Day] of [Month], [Year].
By
[Defendant’s Attorney]
[Firm Name]
[Firm Address]
Attorney for Defendant(s)
On [Date], undersigned:
[Filed/E-filed] the original;
[Mailed/Emailed/Hand Delivered] a copy to: · [Plaintiff’s Counsel]
/s/[Attorney] |