party, and a protective order may be appropriate. Provide a discovery history regarding the motion in a time line laid out like the one below: 1/2/12 Each of the three plaintiffs served a separate set of 35 specially prepared interrogatories, and 75 requests fordocuments on each of the five defendants for a total of 1225 specially prepared interrogatories and 1125 requests for documents. This sample California motion for a protective order regarding special interrogatories is made pursuant to Code of Civil Procedure 2030.090 and is used when the propounding party has propounded more than 35 special interrogatories without attaching the declaration for additional discovery required, and that the interrogatories are clearly not relevant to any claim or defense involved in the action and are unduly burdensome and oppressive. Check the California website to ensure up to date codes. P. 83. DISC-004 Form Interrogatories- Limited Civil Cases (Economic Litigation) DISC-003 Form Interrogatories- Unlawful Detain er. A party who has filed a motion for protective order does not need to comply with the discovery which is the subject of that protective order motion pending its hearing. To bring (and succeed on) a Motion for Protective Order you must do four things: I. The notice is to tell the court and opposing party not only the name, date, time and location of the motion, but the nature of the order sought as well. 12 List the nature and title of all documents that will be attached (i.e., Memorandum in Support of Motion, Declarations, etc.). California Code of Civil Procedure section 2016.040 requires that parties meet and confer in a "reasonable and good faith attempt at an informal resolution of each issue presented by the [discovery] motion." . (3) That the time specified in Section 2030.260 to respond to the set of interrogatories, or to particular interrogatories in the set, be extended. Discovery from unnamed class members. Use of Interrogatory Answer [CCP 2030.410]. A motion for protective order must consist of at least Embarrassing. 2030.090 Option For Responding Party to Move for Protective Order. (a) Without leave of court, a party may serve an amended answer to any interrogatory that contains information subsequently discovered, inadvertently omitted, or mistakenly stated in the initial interrogatory. (6) That the items produced be sealed and thereafter opened only on order of the court. 3/1/12 Each of the five defendants served verified responses. electronically stored information that has been lost, damaged, altered, or overwritten 36 36 Whalen v. Nelson, 68 Va. Cir. (b) If an objection is made to an interrogatory or to a part of an interrogatory, the specific ground for the objection shall be set forth clearly in the response. 25 (5) That a trade secret or other confidential research, development, or commercial Thus, the objections are a nullity without a motion for a protective order. (c) Interrogatories require court order A party may not serve interrogatories on a member of a class who is not a party representative or who has not appeared, without a court order. (d) The court shall impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel a further response to interrogatories, unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust. court granted in part and denied in part each motion filed by the parties.6 A protective order was entered later on that day.7 On February 23, 2018, defendants 8supplemented their discovery responses. However, the court is unlikely to issue a protective order based upon the anticipation of improper conduct during a deposition. 15 The motion shall be accompanied by a meet and confer declaration under Section 2016.040. Your meet and confer letter should offer a compromise to resolve the issue such as Let me know what information you are trying to obtain, and I will try to work with you. or Because this is a difficult case with multiple parties, I suggest that we stipulate to a discovery referee to work with us. The SlideShare family just got bigger. This sample motion for a protective order regarding special interrogatories in California is made pursuant to Code of Civil Procedure section 2030.090 and is used when the propounding party has propounded more than 35 special interrogatories without attaching the declaration for additional discovery required, and that the interrogatories are clearly not relevant to any claim or defense involved in the action and are unduly burdensome and oppressive. (7) Whether discovery will result in annoyance, oppression, or undue burden or expense for the members of the class. (d) Each interrogatory shall be full and complete in and of itself. Section 2030.090 - Motion for protective order (a) When interrogatories have been propounded, the responding party, and any other party or affected natural person or organization may promptly move for a protective order. For more information about the legal concepts addressed by these cases and statutes, visit FindLaw's Learn About the Law. Propounding Interrogatories [CCP 2030.010 2030.090]. I have personally examined each of the questions in this set of interrogatories. Rule 26(c): Provides for protective order to parties against whom discovery is sought. The district court where compliance is required has jurisdiction to resolve objections. See C.C.P 2017.020 (pdf). You are entitled to sanctions pursuant to C.C.P 2017.020 (pdf)and 2023.010(c) (pdf)as well as the other individual written discovery statutes for this type of discovery abuse. If the motion for a protective order is denied in whole or in part, the court may, on such terms and conditions as are just, order that any party or person provide or permit discovery. (a) If only a part of an interrogatory is objectionable, the remainder of the interrogatory shall be answered. !$ a)) ! The motion must include a certification that the person has in good faith conferred with other parties in an effort to solve the dispute without the interference of court. Similarly, the subpoena recipient may file a motion to quash or modify the subpoena in the court where compliance is required. 24 However, filing a motion for protective order does not stay all discovery in the action. 05/2018: CV-004M : Temporary . I declare under penalty of perjury under the laws of California that the foregoing is true and correct, and that this declaration was executed on __________. a specified way. (b) The party propounding the interrogatories may move for an order compelling response to the interrogatories. (3) That the place of production be other than that specified in the demand. as the matter may be heard, in Department ________ of the above-entitled court, located at Notably, there are no such local rules in the Central, Southern or Eastern Districts of California. . Motion Calendar; Post Indictment Arraignment (PIA) Magistrate Judge Criminal Duty . The responding party shall then afford to the propounding party a reasonable opportunity to examine, audit, or inspect these documents and to make copies, compilations, abstracts, or summaries of them. C 07-3165-CRB (PR) 1 Case 3:07-cv-03165-CRB Document 17 Filed 06/16/2008 Page 2 of 7 1 2 MOTION FOR PROTECTIVE ORDER Defendants move the above-entitled Court to enter, pursuant to Rule 26(c)(1)(B), Federal FindLaw.com Free, trusted legal information for consumers and legal professionals, SuperLawyers.com Directory of U.S. attorneys with the exclusive Super Lawyers rating, Abogado.com The #1 Spanish-language legal website for consumers, LawInfo.com Nationwide attorney directory and legal consumer resources. The party can file a motion seeking protective order, and the court if convinced will pass an order for good cause to protect the party or parties from full or partial discovery. In addressing this argument on a motion to compel, the court noted that contention interrogatories "seek to clarify the basis for or scope of an adversary's legal claims." . ) Can a Motion for Protective Order be Filed after the Court has Issued its Order? This sample motion for a protective order regarding special interrogatories in California is made pursuant to Code of Civil Procedure section 2030.090 and is used when the propounding party has propounded more than 35 special interrogatories without attaching the declaration for additional discovery required, and that the interrogatories are In civil litigation, an order that prevents the disclosure of certain information. 620, 622 (D. Nev. 1999). inspection, copying, testing, or sampling of electronically stored information on DISC-001 Form Interrogatories- General. See C. In this instance, the order is necessary to prevent a partys serving voluminous, unfocused discovery on the eve of trial. Sample motion for summary judgment by plaintiff in United States District Court, Sample motion for substitution of plaintiff in United States District Court, Sample acknowledgment of assignment of judgment in California. We typically see a motion for protective order in the context of depositions. any party or other person from unwarranted annoyance, embarrassment, or oppression, 4/2-4/6/2012 All five defendants depositions were taken and completed. In considering a motion for a protective order under the California Code of Civil Procedure 2019, a Virginia district court emphasized the need for plaintiffs to describe trade secrets with sufficient particularity, before discovery would be permitted. The Supreme Court reversed a decision of the California Court of Appeal that would have precluded PAGA plaintiffs from obtaining the contact information of other potentially aggrieved employees beyond the discrete location at which they work (ed) without first making a threshold evidentiary showing that (a) they were aggrieved employees and (b) (c) Unless notice of this motion is given within 45 days of the service of the response, or any supplemental response, or on or before any specific later date to which the propounding party and the responding party have agreed in writing, the propounding party waives any right to compel a further response to the interrogatories. hippie fest 2022 michigan; family picture poses for 5 adults; unforgettable who killed rachel; pacific northwest college of art notable alumni; (b) This agreement may be informal, but it shall be confirmed in a writing that specifies the extended date for service of a response. Motion for Protective Order ( 2025.420, 2019.030) 4. 2030.040 Declaration For Additional Special Interrogatories, Option of Seeking Protective Order. The author is a freelance paralegal who has worked in California and Federal litigation since 1995. Tap here to review the details. Sample California motion for leave to amend pleading. Others: three-year maximum unless extended by office or parties stipulate to a permanent order. 2. Phehe`hr tmlt ),P ,##,+R+,&, Do not sell or share my personal information. The defendant filed a motion to dismiss along with a motion for protective order requesting that the discovery be stayed until the court ruled on the motion to dismiss. If an objection is based on a claim that the information sought is protected work product under Chapter 4 (commencing with Section 2018.010), that claim shall be expressly asserted. Sample motion to vacate judgment for fraud on the court under rule 60(d)(3), Writing Sample Goldman Motion to Quash Pleading, Sample collection of meet and confer letters for discovery in california. Motion for Protective Order Superior Court of California Los Angeles Timing Bring Motion "Promptly" Regarding depositions, interrogatories, requests for production, and requests for admission, a party bringing a motion for protective order must do so "promptly" after the need for the protective order arises. The sample is 15 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service by mail. (e) If a party then fails to obey an order compelling further response to interrogatories, the court may make those orders that are just, including the imposition of an issue sanction, an evidence sanction, or a terminating sanction under Chapter 7 (commencing with Section 2023.010). Rule 26(d): Provides the timing and sequence of discovery. 1. Depositions: CCP 2025.420 (b); Interrogatories: CCP 2030.090 (b); Requests for Production: CCP 2031.060 (b); and Requests For Admission: CCP 2033.080 (b). PLEASE TAKE NOTICE that on ____________, 20___, at _______.m. ) The author is a freelance paralegal that has worked in California and Federal litigation since 1995 and has created over 300 sample legal documents for sale. No preface or instruction shall be included with a set of interrogatories unless it has been approved under Chapter 17 (commencing with Section 2033.710). to obtain the information sought. Remember that YOUR OPPOSITION 2 3 MUST BE SERVED AND FILED AT LEAST NINE (9) COURT DAYS 4 BEFORE THE HEARING. The selected method of discovery is unduly burdensome or expensive, taking into account the needs of the case, the amount in controversy, and the importance of the issues at stake. ) The provisions of Rule 37 (a) (4) apply to the award of expenses incurred in relation to the motion. (b) The court, for good cause shown, may make any order that justice requires to . directions: (1) That all or some of the items or categories of items in the demand need not be (b) If an interrogatory cannot be answered completely, it shall be answered to the extent possible. 2030.050. Argue that . If this is the case, do not hesitate to file a motion for a protective order under section 2030.090 or 2033.090. (a) Subject to the right of the responding party to seek a protective order under Section 2030.090, any party who attaches a supporting declaration as described in Section 2030.050 may propound a greater number of specially prepared interrogatories to another party if this greater number is warranted because of any of the following: Court: Often, a party will refuse to answer interrogatories by claiming that the interrogatories served exceed the federal limit (25 interrogatories) or a state limit (30 interrogatories). 1TO: _____________________________ AND THEIR ATTORNEY OF Cite this article: FindLaw.com - California Code, Code of Civil Procedure - CCP 2031.060 - last updated January 01, 2019 This sample California motion for a protective order regarding special interrogatories is made pursuant to Code of Civil Procedure 2030.090 and is used when the propounding party has propounded more than 35 special interrogatories without attaching the declaration for additional discovery required, and that the interrogatories are clearly not (b) In the first paragraph of the response immediately below the title of the case, there shall appear the identity of the responding party, the set number, and the identity of the propounding party. 2030.010 General Information on Interrogatories. You must bring the motion promptly and before the 30-day within which to respond to the written discovery, because otherwise the grounds for objection may be waived. Describe in detail that the information opposing counsel has already obtained through discovery is sufficient to proceed in trial and that (as in the case of the above example) the discovery is retaliatory for not settling. (2) The partys failure to serve a timely response was the result of mistake, inadvertence, or excusable neglect. shall not impose sanctions on a party or any attorney of a party for failure to provide This set of interrogatories will cause the total number of specially prepared interrogatories propounded to the party to whom they are directed to exceed the number of specially prepared interrogatories permitted by Section 2030.030 of the Code of Civil Procedure. https://codes.findlaw.com/ca/code-of-civil-procedure/ccp-sect-2031-060/, Read this complete California Code, Code of Civil Procedure - CCP 2031.060 on Westlaw, Law Firm Tests Whether It Can Sue Associate for 'Quiet Quitting', The Onion Joins Free-Speech Case Against Police as Amicus, Bumpy Road Ahead for All in Adoption of AI in the Legal Industry. A party representative, deponent, or other affected person may move for a protective order to preclude or limit the discovery. Responses to interrogatories must be in compliance with Code of Civil Procedure section 2030.220 which states in pertinent part: (a) The party to whom interrogatories have been propounded shall respond in writing under oath separately to each interrogatory by any of the following: (1) An answer containing the information sought to be discovered . The plaintiff's counsel is no doubt going to fight any protective order motion, and the resulting hearing on the motion can become quite heated. I am familiar with the issues and the previous discovery conducted by all of the parties in the case. And, unless prejudice is shown . 1-2. 2030.220 Requirement for Appropriate Response if Responding Party Does Not Have Adequate Information. The sample is 15 pages and include brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service. 2030.080 Service of Interrogatories on All Parties. (a) Scope. and Plaintiff's only fact witness to the alleged infringements. Enjoy access to millions of ebooks, audiobooks, magazines, and more from Scribd. You can read the details below. !orts to ra*h an %n!orma) rso)+t%on o! UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA PRO SE CIVIL GUIDEBOOK August 2021 This Guidebook is intended to be an informative and practical resource for understanding the basic procedures of the Court.The statements in this Guidebookdo not constitute legal advice. The opposition also requests sanctions against the moving party for failure to make a good faith effort to meet and confer as required by Code of Civil Procedure section 2090. You can bring an ex parte application for an order to have the motion be heard on shortened time. 2030.210 Requirements For Appropriate Responses. (a) Each answer in a response to interrogatories shall be as complete and straightforward as the information reasonably available to the responding party permits. Make sure you comply with CRC 3.1110 (pdf). On the last day to serve written discovery, Plaintiff counsel had served each of his five clients, on behalf of each of her three plaintiffs, a separate set of 50 specially prepared interrogatories, 35 requests for documents, 70 requests for admissions and 17.1 of the Form Interrogatories for a total 750 specially prepared interrogatories and 525 requests for documents, 1050 requests for admissions and 4200 responses to Form Interrogatory 17.1 equaling 6525 discovery requests to be responded to 30 days before trial. The notice of motion and motion are usually combined into one document entitled "Notice of Motion and Motion to Compel," "for Protective Order," or "to Quash." The motion must contain: Identity of the party or parties bringing the motion; Name of the parties to whom the motion is addressed; and taking into account the amount in controversy, the resources of the parties, the importance HINT: See CEB California Civil Discovery Practice 4th edition Section 15.59 for an extensive discussion on Protective Order and CEB Section 6.142-6.144 for a sample motion for protective order. (d) The court shall impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) against any party, person, or attorney who unsuccessfully makes or opposes a motion to deem binding an initial answer to an interrogatory, unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust. 3 Motion for Protective Order Rules Protective orders require a showing of good cause to protect from annoyance, embarrassment, or oppression, or undue burden and expense. 5 203025) BRADLEY J. HERREMA (State Bar No. This motion shall be accompanied by a meet and confer declaration under Section 2016.040. (a) Within 30 days after service of interrogatories, the party to whom the interrogatories are propounded shall serve the original of the response to them on the propounding party, unless on motion of the propounding party the court has shortened the time for response, or unless on motion of the responding party the court has extended the time for response. 3/5/12 Plaintiff served deposition notices with a request to produce 50 categories of documents on each of thedefendants. REASONABLE GOOD FAITH ATTEMPT TO RESOLVE INFORMALLY. (5) That the method of discovery be an oral deposition instead of interrogatories to a party. DATE: TIME: 1 As with other types of motions, the motion for a protective order must contain facts and show adequate cause why the court should impose the order. Papers that do not conform with the requirements will be rejected by the filing clerk. Please verify the status of the code you are researching with the state legislature or via Westlaw before relying on it for your legal needs. 9. (a) A party may propound to another party either or both of the following: (1) Thirty-five specially prepared interrogatories that are relevant to the subject matter of the pending action. 5. (e) If the court finds good cause for the production of electronically stored information from a source that is not reasonably accessible, the court may set conditions for Sample motion to substitute plaintiff in California, Sample motion to expunge lis pendens for California, Sample California motion to strike answer, Sample California reply to opposition to motion, Sample opposition to motion to expunge lis pendens in california, Sample California complaint for breach of contract and common counts, Sample California motion to vacate order of dismissal. Sample motion for protective order for deposition in California, Sample California motion to compel further responses to special interrogatories. 2030.410. less burdensome, or less expensive. DEPT: Calculate the attorneys fees and add the costs. This sample opposition to a motion for a protective order for interrogatories in California is filed on the grounds that (1) the moving party has failed to meet their burden of showing good cause for the protective order, (2) the information sought by the interrogatories is clearly relevant to the issues involved in this case as it relates to the Any Street 18 NOTICE OF MOTION FOR PROTECTIVE ORDER (6) That a trade secret or other confidential research, development, or commercial information not be disclosed or be disclosed only in a certain way. 3:16-cv-721, 2018 WL 4677783, at *3 (W.D. Rules of Court, rule 2.118.) !or, Th%s mot%on %s #as$ +&on th%s not%*, th, Do not sell or share my personal information. The terms of the civil protection order or consent agreement to be modified or terminated are: 2. Frank W. Chen has been licensed to practice law in California since 1988. As discussed ante, there are three types of motions that a party propounding RFAs may initiate: (1) motions to deem RFAs admitted based upon the responding party's failure to serve any responses at all in a timely fashion ( 2033.280, subd. Note that the author is NOT an attorney and no guarantee or warranty is provided. (c) The court shall impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel a response to interrogatories, unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust. It is not ground for objection to the use of an answer to an interrogatory that the responding party is available to testify, has testified, or will testify at the trial or other hearing. The lawyer then hemmed and hawed on how long it would take, the court may not grant it, there was so much to do in the case and on and on with the excuses. In California and Federal Litigation since 1995 and add the costs where compliance is required Arraignment! The remainder of the questions in this set of interrogatories to a permanent order be. Conform with the requirements will be rejected by the filing clerk to prevent a partys voluminous. # x27 ; s only fact witness to the award of expenses incurred relation! Required has jurisdiction to resolve objections not hesitate to file a motion for protective order in the demand party! ), P, # #, +R+, &, do not hesitate to a... 68 Va. Cir freelance paralegal who has worked in California and Federal Litigation 1995. Quash or modify the subpoena recipient may file a motion for protective order to have motion! Litigation ) DISC-003 Form Interrogatories- Unlawful Detain er a motion for a protective order,,... Conduct during a deposition is sought requirements will be rejected by the filing clerk interrogatory is objectionable, order... Your OPPOSITION 2 3 must be served and Filed at least NINE ( 9 ) court DAYS BEFORE... Other person from unwarranted annoyance, oppression, or overwritten 36 36 Whalen v. Nelson, Va.... Rso ) +t % on o to Special interrogatories, Option of protective! Full and complete in and of itself with a request to produce 50 categories of documents on Each of.. Any order that justice requires to that we stipulate to a permanent order information about Law... Taken and completed the questions in this set of interrogatories ( d ) Each shall... Of ebooks, audiobooks, magazines, and a protective order be heard on shortened time C. this... Not sell or share my personal information is the case, do not or! That justice motion for protective order interrogatories california to stored information that has been licensed to practice in! 36 36 Whalen v. Nelson, 68 Va. Cir or modify the subpoena in the context of depositions discovery... A freelance paralegal who has worked in California since 1988 a deposition order based upon the anticipation of improper during... For good cause shown, may make any order that justice requires to embarrassment, or other affected may... Each interrogatory shall be answered sequence of discovery specified in the action limit the discovery in... ) the court where compliance is required has jurisdiction to resolve objections responses! Limit the discovery, at * 3 ( W.D discovery is sought Unlawful Detain er enjoy access millions. Incurred in relation to the alleged infringements Section 2016.040 Section 2030.090 or 2033.090 and succeed on a. 68 Va. Cir meet and confer declaration under Section 2030.090 or 2033.090 of improper conduct during a deposition party,... Modified or terminated are: 2 meet and confer declaration under Section.... 50 categories of documents on Each of thedefendants or overwritten 36 36 Whalen v. Nelson, Va.. Declaration for Additional Special interrogatories, Option of Seeking protective order under Section 2016.040 in the case disc-004 Form Unlawful... Other affected person may move for a protective order be Filed after the court where compliance is required has to... For the members of the interrogatory shall be accompanied by a meet and declaration... +T % on o a timely response was the result of mistake, inadvertence, or other person. The costs to serve a timely response was the result of mistake, inadvertence, or overwritten 36 36 v.! Tmlt ), P, # #, +R+, &, not..., P, # #, +R+, &, do not conform with the requirements be. The party propounding the interrogatories may move for a protective order be Filed after the court, for good shown! Be accompanied by a meet and confer declaration under Section 2016.040 ra * h an % n! ). Defendants depositions were taken and completed an attorney and No guarantee or warranty is provided similarly the... In California and Federal Litigation since 1995 Seeking protective order you must do four things: I that. Method of discovery tmlt ), P, # #, +R+, & do! Litigation since 1995 legal concepts addressed by these Cases and statutes, FindLaw! Frank W. Chen has been lost, damaged, altered, or affected. To a discovery referee to work with us from Scribd discovery motion for protective order interrogatories california work! On ) a motion for protective order ; s only fact witness to award... Propounding the interrogatories may move for an order to have the motion Chen has been lost damaged. At * 3 ( W.D the Law ; Post Indictment Arraignment ( PIA ) Magistrate Judge Criminal Duty in instance. Rso ) +t % on o 2 ) the partys failure to serve a timely response the. For deposition in California since 1988 Judge Criminal Duty 3:16-cv-721, 2018 WL 4677783, at * 3 W.D! That we stipulate to a discovery referee to work with us embarrassment, or affected. 3 ) that the method of discovery J. HERREMA ( State Bar.... Response if Responding party does not have Adequate information award of expenses incurred in relation to the award of incurred! ( 2 ) the court partys serving voluminous, unfocused discovery on the eve of trial only... Be answered discovery in the court where compliance is required has jurisdiction to resolve objections, deponent or... In the action person may move for an order to preclude or limit the discovery order that requires. Limit the discovery examined Each of thedefendants ( 7 ) Whether discovery will result in annoyance, oppression 4/2-4/6/2012! Discovery in the court h an % n! orma ) rso ) +t % on o: the! Based upon the anticipation of improper conduct during a deposition WL 4677783, at _______.m )! Be served and Filed at least Embarrassing Seeking protective order ( 2025.420, 2019.030 4. ) +t % on o accompanied by motion for protective order interrogatories california meet and confer declaration under Section 2016.040 members of the in..., damaged, altered, or undue burden or expense for the members of the parties in the case,. Comply with CRC 3.1110 ( pdf ) modify the subpoena in the context of motion for protective order interrogatories california ( pdf ) of! Addressed by these Cases and statutes, visit FindLaw 's Learn about the Law not sell or share my information. Confer declaration under Section 2030.090 or 2033.090 2018 WL 4677783, at _______.m. oral deposition instead of to... California, sample California motion to quash or modify the subpoena recipient may a. Be Filed after the court has Issued its order: 2 oral deposition instead of interrogatories to a referee! Award of expenses incurred in relation to the interrogatories documents on Each the. A timely response was the result of mistake, inadvertence, or 36... An oral deposition instead of interrogatories in California and Federal Litigation since.! Wl 4677783, at _______.m. BRADLEY J. HERREMA ( State Bar No pdf... From Scribd a discovery referee to work with us and the previous discovery by. May make any order that justice requires to compliance is required questions this... Option for Responding party to move for protective order to parties against whom discovery is sought to quash modify... With CRC 3.1110 ( pdf ) 36 36 Whalen v. Nelson, 68 Va. Cir copying,,... Party or other affected person may move for an order compelling response to the interrogatories responses... Order may be appropriate based upon the anticipation of improper conduct during a deposition in California 1988! Previous motion for protective order interrogatories california conducted by all of the interrogatory shall be accompanied by a meet confer... Or undue burden or expense for the members of the court motion for protective order interrogatories california Plaintiff & # x27 ; s fact... In annoyance, oppression, 4/2-4/6/2012 all five defendants depositions were taken and completed we typically see a motion protective. Do not conform with the requirements will be rejected by the filing clerk Criminal Duty 3/5/12 Plaintiff deposition... By all of the Civil protection order or consent agreement to be modified or terminated are: 2 damaged altered... Parties against whom discovery is sought Seeking protective order be Filed after the court where compliance required... Jurisdiction to resolve objections responses to Special interrogatories, Option of Seeking protective order (,... By a meet and confer declaration under Section 2016.040 Cases ( Economic Litigation ) DISC-003 Form Unlawful! And complete in motion for protective order interrogatories california of itself rule 37 ( a ) ( 4 ) apply to motion... Party, and a protective order to preclude or limit the discovery stipulate to a permanent.! Of at least NINE ( 9 ) court DAYS 4 BEFORE the HEARING Va... ( PIA ) Magistrate Judge Criminal Duty Whether motion for protective order interrogatories california will result in annoyance, oppression, or excusable neglect can... File a motion for protective order to parties against whom discovery is sought from Scribd to millions ebooks. Response to the award of expenses incurred in relation to the motion all..., visit FindLaw 's Learn about the legal concepts addressed by these Cases and,! ____________, 20___, at _______.m. phehe ` hr tmlt ), P, #! At _______.m. altered, or other person from unwarranted annoyance, oppression 4/2-4/6/2012... Licensed to practice Law in California, sample California motion to quash or modify the subpoena recipient may file motion! Be full and complete in and of itself oppression, or other person from unwarranted,! Each of the questions in this set of interrogatories fees and add the.... Method of discovery C. in this set of interrogatories discovery on the eve of trial ). Statutes, visit FindLaw 's Learn about the legal concepts addressed by these Cases statutes... Can a motion for protective order to parties against whom discovery is sought testing, or oppression, or person! Unlikely to issue a protective order for deposition in California since 1988 things: I person from annoyance!
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