Sample Motion for Protective Order for Deposition in California

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This sample motion for a protective order for a deposition in California is filed pursuant to Code of Civil Procedure section 2025.420(b) on the grounds that the moving party will suffer unwarranted annoyance, embarrassment, or oppression, or undue burden and expense if the court does not grant the motion for a protective order.  The sample has been revised and updated in March 2018, is 18 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 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.