Q: Sample motions language

A: Here are some sample motion phrases and links to resources that may be helpful for the two motions you described under California law:

Motion for Court's Order to Defendant Hospital to Disclose Private Information of Service Providers:

Key Phrases:

- Plaintiff respectfully moves this Court for an order compelling Defendant [Hospital Name] to disclose the identities and contact information of [specify service providers or third parties] pursuant to California Code of Civil Procedure § 2017.010, on the grounds that such information is relevant to the subject matter of this action and reasonably calculated to lead to the discovery of admissible evidence.

- This information is necessary for Plaintiff to investigate [specify reasons].

- Plaintiff has in good faith conferred or attempted to confer with Defendant in an effort to resolve this dispute without court action.

Motion for In Camera Review of Privilege Log:

Key Phrases:

- Plaintiff moves for an order requiring Defendant to produce documents withheld on the basis of privilege for in camera inspection by the Court pursuant to California Evidence Code § 915(b), on the grounds that an examination of the documents themselves is necessary to evaluate Defendant's claims of [attorney-client privilege and/or attorney work product].

- Plaintiff has made a prima facie showing that the documents are not privileged, by [specify reasons].

- In camera review is needed because [explain why more information is required to assess the privilege claims].

Keep in mind this is just sample language and each motion should be tailored to the specific facts and circumstances of your case. Be sure to check and comply with your court's local rules for filing motions as well. Consulting with a licensed California attorney is recommended.