Sample Motion for Protective Order Regarding Requests for Admission in California

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This sample motion for protective order regarding requests for admission in California is filed pursuant to Code of Civil Procedure section 2033.080 on the grounds that more than 35 requests for admission were propounded yet no declaration for additional discovery was included as required by Code of Civil Procedure section 2033.050, and on the further grounds that the requests for admission clearly do not relate to any conceivable triable issues in the case, and that they are unduly burdensome and oppressive.  The sample 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.