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

Sample Opposition to Motion for Protective Order for Documents in California

$25.99 Sale

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

This sample opposition to a motion for a protective order regarding requests for production of documents 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 documents requested are clearly relevant to the issues involved in this case they relate to the claim or defense of the moving party and therefore meet the relevancy standard imposed by Code of Civil Procedure § 2017.010,
  • (3) the requests for production of documents are not overbroad and oppressive or vague and ambiguous, and
  • (4) that the requests for production of documents are not excessive. 

The opposition also requests sanctions pursuant to Code of Civil Procedure section 2031.060(h) on the grounds that the moving party failed to make a reasonable good faith effort to meet and confer before filing the motion for a protective order.

The sample has been revised and updated in 2019, is 14 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.