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Sample opposition to motion for protective order for interrogatories in California.

Sample Opposition to Motion for Protective Order for Interrogatories in California

$32.49 Sale

Sample Opposition to Motion for Protective Order for Interrogatories in California.

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 claim or defense of the moving party and therefore meets the relevancy standard imposed by Code of Civil Procedure section 2017.010,
  • (3) the interrogatories are not overbroad and oppressive or vague and ambiguous, and
  • (4) that the interrogatories are not excessive and were served with a valid, executed declaration for additional discovery in compliance with Code of Civil Procedure sections 2030.040(a) and 2030.050.

The opposition also requests sanctions against the moving party for failure to make a good faith effort to meet and confer as required by California law. 

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.

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.

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