Sample Motion for Protective Order Regarding Requests for Admission for California.

Sample Motion for Protective Order Regarding Requests for Admission for California

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Sample Motion for Protective Order Regarding Requests for Admission for California.

This sample motion for a protective order regarding requests for admission in California is made pursuant to Code of Civil Procedure section 2033.080 and is used when the propounding party has propounded more than 35 requests for admission interrogatories without attaching the declaration for additional discovery required by Code of Civil Procedure section 2033.050, and that the requests for admission are clearly not relevant to any conceivable triable issue involved in the action and are unduly burdensome and oppressive.

The sample motion also requests sanctions.

The sample has been revised and updated in 2019, is 15 pages and includes,

  • Brief instructions,
  • Memorandum of points and authorities with citations to case law and statutory authority,
  • Sample declaration, and
  • Proof of service by mail.

The author is an entrepreneur and retired litigation paralegal that worked in California and Federal litigation from January 1995 through September 2017 and has created over 300 sample legal documents for sale.

Note that the author is NOT an attorney and no guarantee or warranty is provided.