Sample Opposition to Motion for Protective Order for Admissions in California

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This sample opposition to a motion for a protective order for requests for admission 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 requests for admission are clearly relevant to triable issues of material fact involved in this case they relate to the claim or defense of the moving party and therefore meets the relevancy standard imposed by Code of Civil Procedure § 2017.010, (3) that the requests for admission are not overbroad and oppressive or vague and ambiguous, and (4) the requests for admission are not excessive. The opposition also requests sanctions pursuant to Code of Civil Procedure section 2033.080(d) on the grounds that the moving party filed their motion for a protective order without a showing of good cause or making a reasonable good faith effort to meet and confer. 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. 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.