Sample Motion For Protective Order For Deposition in California
Uploaded by
Stan BurmanSample Motion For Protective Order For Deposition in California
Uploaded by
Stan Burman1 Any Attorney or Party
Any Street
2 Any Town, CA 55555
3 714-555-5555
4 Any Attorney or Party
8 Superior Court of the State of California
9 For the County _________________
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11 Any Plaintiff, ) Case No.
)
12 NOTICE OF MOTION FOR PROTECTIVE ORDER
Plaintiff, )
REGARDING DEPOSITION OF __________;
)
13 AND FOR MONETARY SANCTIONS IN THE
vs. )
AMOUNT OF $_________, MEMORANDUM OF
)
14 POINTS AND AUTHORITIES, DECLARATION OF
Any Defendant, )
__________, EXHIBITS
)
15 Defendant. ) DATE: TIME:
) DEPT:
16 )
)
17 )
)
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NOTICE OF MOTION AND MOTION FOR PROTECTIVE ORDER-DEPOSITION
1 Be sure to remove this notice and all other notices before using
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this document.
4 TO: _____________________________ AND THEIR ATTORNEY OF RECORD HEREIN:
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PLEASE TAKE NOTICE that on ____________, 20___, at _______.m. or as soon thereafter
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as the matter may be heard, in Department ________ of the above-entitled court, located at
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__________________________, ___________________________will and hereby does move this
9 Court:
10 1. For a protective order that LIST HERE THE SPECIFIC ORDER THAT YOU
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SEEK SUCH AS CERTAIN INDIVIDUALS SHALL NOT BE PRESENT AT THE
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DEPOSITION, THE DEPOSITION BE TAKEN ON A DIFFERENT DATE, THE
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DEPOSITION NOT BE TAKEN AT ALL, ETC., on the grounds that LIST HERE THE
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15 SPECIFIC FACTS AND EVIDENCE THAT SUPPORT YOUR REQUEST FOR A
16 PROTECTIVE ORDER SUCH AS UNLESS A PROTECTIVE ORDER IS ISSUED THE
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MOVING PARTY WILL SUFFER UNWARRANTED ANNOYANCE, EMBARASSMENT,
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OPPRESSION OR UNDUE BURDEN AND EXPENSE.
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2. For a protective order that the moving party need not produce any of the requested
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21 documents in categories __ through ___ at the deposition on the grounds that unless a protective
22 order is issued the moving party will suffer unwarranted annoyance, embarrassment, or oppression,
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or undue burden and expense pursuant to Code of Civil Procedure 2025.420(b); and
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3. For an order of sanctions as against ______________________________, in the
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amount of $____________ for their blatant failure and refusal to meet and confer in a reasonable
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27 good faith effort to reach an informal resolution of this matter.
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NOTICE OF MOTION AND MOTION FOR PROTECTIVE ORDER-DEPOSITION
1 This motion is brought pursuant to Code of Civil Procedure 2025.420 et seq., on the
2 grounds that unless a protective order is issued the moving party will suffer unwarranted annoyance,
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embarrassment, or oppression, or undue burden and expense pursuant to Code of Civil Procedure
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2025.420(b) and on the further grounds that the requested documents do not relate in any way to the
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claim or defense of either the requesting party nor any other party to this action and thus the requests
7 fail to meet the relevancy standard imposed by Code of Civil Procedure 2017.010.
8 The moving party further requests the sum of $___________ in sanctions against
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_____________________ pursuant to Code of Civil Procedure 2025.420(h).
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This Motion is made upon the grounds that ____________ the moving party has made
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reasonable good faith efforts to reach an informal resolution of this matter without the need for
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13 judicial intervention but ___ has rebuffed all efforts.
14 This motion is based upon this notice, the attached memorandum of points and authorities,
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declaration of _____________, and exhibits, and upon such further oral and documentary evidence
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as may be presented to the Court by at the time of the hearing.
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19 Dated________________ _______________________________________________
ANY ATTORNEY OR PARTY
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NOTICE OF MOTION AND MOTION FOR PROTECTIVE ORDER-DEPOSITION
