Sample Motion for Protective Order Regarding Requests for Admission for California

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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 March 2018, 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. The author is a freelance paralegal that has worked in California and Federal litigation since 1995. Note that the author is NOT an attorney and no guarantee or warranty is provided.