Sample Motion for Protective Order Regarding Production of Documents for California

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This sample motion for protective order regarding requests for production of documents in California is made pursuant to Code of Civil Procedure section 2031.060 on the grounds that none of the requested documents relate to the claim or defense of either the requesting party nor any other party to this action and thus the requests for production of documents fail to meet the relevancy standard imposed by California law, and that unless a protective order is issued the moving party will suffer unwarranted annoyance, embarrassment, or oppression, or undue burden and expense. The sample is 16 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 an entrepreneur and 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.