accessible because of undue burden or expense, the court may nonetheless order discovery This sample motion for a protective order regarding special interrogatories in California is made pursuant to Code of Civil Procedure section 2030.090 and is used when the propounding party has propounded more than 35 special interrogatories without attaching the declaration for additional discovery required, and that the interrogatories are clearly not relevant to any claim or defense involved in the action and are unduly burdensome and oppressive. Thus, a motion for protective order should be denied if it wasn't file within the 30-days to respond. Please verify the status of the code you are researching with the state legislature or via Westlaw before relying on it for your legal needs. __________________________, ___________________________will and hereby do move this This motion shall be accompanied by a meet and confer declaration under Section 2016.040. At FindLaw.com, we pride ourselves on being the number one source of free legal information and resources on the web. 2030.290. 4. (5) That a trade secret or other confidential research, development, or commercial Click here to review the details. FindLaw Codes may not reflect the most recent version of the law in your jurisdiction. (b) A plaintiff may propound interrogatories to a party without leave of court at any time that is 10 days after the service of the summons on, or appearance by, that party, whichever occurs first. 5/9/2012 On the last day to hand serve written discovery, each of the three plaintiffs served separate set of 50 specially prepared interrogatories, 35 requests for documents, 70 requests for admissions and 17.1 of the FormInterrogatories for a total of on each of the five defendants for a total of 750 specially preparedinterrogatories and 525requests for documents, 1050requests for admissions and 4200 responses to FormInterrogatory 17.1. Petition for Temporary Protective Order. Plaintiffs filed this motion on March 6, 2018.9 On March 8, 2018, defendants produced 5,656 documents consisting of more than 26,000 pages. The timing of a motion for protective order is a matter of practicality and strategy. (3) That the place of production be other than that specified in the demand. to obtain the information sought. A limitation on the terms and conditions of the deposition. 26 Feb Feb At the trial of the action, the propounding party or any other party may use the initial answer under Section 2030.410, and the responding party may then use the amended answer. 4 By accepting, you agree to the updated privacy policy. (a) The party to whom interrogatories have been propounded shall respond in writing under oath separately to each interrogatory by any of the following: (1) An answer containing the information sought to be discovered. You need to look like the reasonable one!! 2030.230. On the last day to serve written discovery, Plaintiff counsel had served each of his five clients, on behalf of each of her three plaintiffs, a separate set of 50 specially prepared interrogatories, 35 requests for documents, 70 requests for admissions and 17.1 of the Form Interrogatories for a total 750 specially prepared interrogatories and 525 requests for documents, 1050 requests for admissions and 4200 responses to Form Interrogatory 17.1 equaling 6525 discovery requests to be responded to 30 days before trial. (a) The party propounding interrogatories shall serve a copy of them on the party to whom the interrogatories are directed. (c) Notwithstanding subdivision (b), in an unlawful detainer action or other proceeding under Chapter 4 (commencing with Section 1159) of Title 3 of Part 3, a plaintiff may propound interrogatories to a party without leave of court at any time that is five days after service of the summons on, or appearance by, that party, whichever occurs first. The motion must be accompanied by a declaration stating facts showing a "reasonable and good faith attempt" to resolve the matter outside of court. 22 Rule 3.768. (b) The court, for good cause shown, may make any order that justice requires to protect Sample motion to vacate judgment for fraud on the court under rule 60(d)(3), Writing Sample Goldman Motion to Quash Pleading, Sample collection of meet and confer letters for discovery in california. Specifically, in Georgia if a party fails to respond to a discovery request, or fails to respond to a question propounded during a deposition, the requesting party may "move for an order compelling an answer, or a designation, or an order compelling inspection in accordance with the request." O.C.G.A. (2) An exercise of the option to produce documents under Section 2030.230 is unwarranted or the required specification of those documents is inadequate. California Rules of Court, Rule 3.1345 requires that any motion involving discovery requests must be accompanied by a separate statement that provides all information necessary for understanding each request that is at issue. information. (c) Each answer, exercise of option, or objection in the response shall bear the same identifying number or letter and be in the same sequence as the corresponding interrogatory, but the text of that interrogatory need not be repeated. This set of interrogatories contains a total of __________ specially prepared interrogatories. Interrogatories (ROGs), and Requests to Admit (RFAs), served on May 19, 2022. Any Attorney or Party or expense. A-Z, Form (Long Decl 6, Ex. They helped me a lot once. In lieu of or in addition to that sanction, the court may impose a monetary sanction under Chapter 7 (commencing with Section 2023.010). ) because of undue burden or expense shall bear the burden of demonstrating that the 1-2. Sample verified complaint for financial elder abuse in California. The plaintiff's counsel is no doubt going to fight any protective order motion, and the resulting hearing on the motion can become quite heated. tmlt tmh fjthrrckltcrfhs lrh jct cvhr`rclb ljb, cpprhssfvh cr vlkuh ljb le`fkucus, ljb (") tmlt tmh fjthrrckltcrfhs lrh jct h#nhssfvh ljb whrh, aurtmhr rh%uhsts tmh sue ca &'''' fj sljntfcjs lklfjst, 04!444 cj tmh krcujbs tmlt tmh ecvfjk plrty, afohb tmhfr ectfcj acr l prcthntfvh crbhr wftmcut l smcwfjk, mh Cppcsftfcj smloo `h `lshb cj tmfs Cppcsftfcj, tmh lttlnmhb ehecrljbue ca pcfjts ljb, lutmcrftfhs, tmh bhnolrltfcj ca '''''''''''ljb h#mf`fts lttlnmhb tmhrhtc, cj tmh ncepohth afohs ljb, rhncrbs ca tmfs lntfcj, ljb cj sunm ctmhr crlo ljb*cr bcnuehjtlry hvfbhjnh ls ely `h prhshjthb lt tmh, lthb'''''''''''''''' ''''''''''''''''''''''''''''''''''''''''''''''', tc ycur plrtfnuolr sftultfcj. motion for a protective order. file a motion for protective order pursuant to Code of Civil Procedure 2019.030 and 2030.090. (a) Subject to the right of the responding party to seek a protective order under Section 2030.090, any party who attaches a supporting declaration as described in Section 2030.050 may propound a greater number of specially prepared interrogatories to another party if this greater number is warranted because of any of the following: (d) If the party or affected person from whom discovery of electronically stored information POINTS AND AUTHORITIES, DECLARATION DEPT: 23 2 ) A. is sought establishes that the information is from a source that is not reasonably (c) If the responding party does not have personal knowledge sufficient to respond fully to an interrogatory, that party shall so state, but shall make a reasonable and good faith effort to obtain the information by inquiry to other natural persons or organizations, except where the information is equally available to the propounding party. Does the 45-Day Rule Apply when no Privilege Log was Served? 9____________ !or th%r #)atant !a%)+r an$ r!+sa) to mt an$ *on!r %n a rasona#), ro+n$s that ____________ &ro&o+n$$ mor than /3 s&*%a))" &r&ar$ %ntrroator%s %tho+t, %n*)+$%n th s+&&ort%n $*)arat%on r1+%r$ #" )a, an$ has &ro&o+n$$, %ntrroator%s that *)ar)" $o not r)at to th *)a%m, an" othr &art" to th a*t%on as r1+%r$ #", ro+n$s that th %ntrroator%s ar +n$+)" #+r$nsom, Th mo'%n &art" !+rthr r1+sts &+rs+ant to. Whatever the reason behind this absurd amount of discovery, he needed to file a motion for a protective order. (b) In the first paragraph immediately below the title of the case, there shall appear the identity of the propounding party, the set number, and the identity of the responding party. Contact us. CA Civ Pro Code 2030.090 (2017) (a) When interrogatories have been propounded, the responding party, and any other party or affected natural person or organization may promptly move for a protective order. Defendant. s+m o! be extended. (4) That the response be made only on specified terms and conditions. 14 3:16-cv-721, 2018 WL 4677783, at *3 (W.D. Sample demurrer for another action pending in California, California discovery document collection for sale, California unlawful detainer (eviction) document collection for sale, Sample ex parte application for osc for civil contempt in California, Sample motion for vocational evaluation in California divorce, Sample opposition to order to show cause for civil contempt in California, Sample student loan debt validation letter, Sample opposition to motion for terminating sanctions in California, Sample petition for final distribution for probate in California. 95.) The following types of discovery may be sought, through service of a subpoena and without a court order, from a member of a class who is not a party representative or who has not appeared: (3) A deposition for production of business records and things. This sample opposition to a motion for a protective order for interrogatories 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 information sought by the interrogatories is clearly relevant to the issues involved in this case as it relates to the claim or defense of the moving party and therefore meets the relevancy standard imposed by Code of Civil Procedure section 2017.010, (3) that the interrogatories are not overbroad and oppressive or vague and ambiguous, and (4) that the interrogatories are not excessive and were served with a valid, executed declaration for additional discovery in compliance with Code of Civil Procedure sections 2030.040(a) and 2030.050. ) (e) If a party then fails to obey an order compelling further response to interrogatories, the court may make those orders that are just, including the imposition of an issue sanction, an evidence sanction, or a terminating sanction under Chapter 7 (commencing with Section 2023.010). Code Civ. As with the motion for . 2030.230 Responding Party Does Not Have to Make a Compilation, Abstract, Audit, or Summary of Documents. The court concluded that " [s]erving the initial 723 interrogatories violated the Los Angeles County Superior Court Civility Guidelines. Riverside Superior Court, and all other California trial courts, for a substantial period of time, the disruption to court business has been extensive. (a) When interrogatories have been propounded, the responding party, and any other party or affected natural person or organization may promptly move for a protective order. MOTION for Protective Order PREVENTING THE DEPOSITION OF STEVE JOBS filed by Apple Inc.. Motion Hearing set for 1/18/2011 10:00 AM in Courtroom 2, 5th Floor, San Jose. as the result of the routine, good faith operation of an electronic information system. from a source that is not reasonably accessible, the court may set conditions for 2030.290 Remedies If a Party Fails To Serve a Response. (b) Motion for protective order A party representative, deponent, or other affected person may move for a protective order to preclude or limit the discovery. In lieu of or in addition to that sanction, the court may impose a monetary sanction under Chapter 7 (commencing with Section 2023.010). (3) An objection to an interrogatory is without merit or too general. Motion for Protective Order Superior Court of California Los Angeles Timing Bring Motion "Promptly" Regarding depositions, interrogatories, requests for production, and requests for admission, a party bringing a motion for protective order must do so "promptly" after the need for the protective order arises. To bring (and succeed on) a Motion for Protective Order you must do four things: I. > > Read More.. You can read the details below. Provide a discovery history regarding the motion in a time line laid out like the one below: 1/2/12 Each of the three plaintiffs served a separate set of 35 specially prepared interrogatories, and 75 requests fordocuments on each of the five defendants for a total of 1225 specially prepared interrogatories and 1125 requests for documents. The provisions of Rule 37 (a) (4) apply to the award of expenses incurred in relation to the motion. The opposition also requests sanctions against the moving party for failure to make a good faith effort to meet and confer as required by Code of Civil Procedure section 2090. Argue that . Proc. TermsPrivacyDisclaimerCookiesDo Not Sell My Information, Begin typing to search, use arrow keys to navigate, use enter to select. In deciding whether to allow the discovery requested under (a) or (c), the court must consider, among other relevant factors: (3) The materiality of the information being sought; (4) The likelihood that class members have such information; (5) The possibility of reaching factual stipulations that eliminate the need for such discovery; (6) Whether class representatives are seeking discovery on the subject to be covered; and. In civil litigation, an order that prevents the disclosure of certain information. As with other types of motions, the motion for a protective order must contain facts and show adequate cause why the court should impose the order. 3/1/12 Each of the five defendants served verified responses. (g) If the motion for a protective order is denied in whole or in part, the court 4/2-4/6/2012 All five defendants depositions were taken and completed. 969G Edgewater Blvd., Suite 345 Foster City, CA 94404 phone: (650)571-1011 fax: (650)571-0793 klgallo@discoveryreferee.com . 6 (a) Before, during, or after a deposition, any party, any deponent, or any other affected natural person or organization may promptly move for a protective order. REMEMBER this declaration needs to be from the attorney who has personal knowledge of what has been happening on the discovery. Why is the court reopening discovery on cases where the discovery cut-off date had passed This motion shall be accompanied by a meet and confer declaration under Section 2016.040. This motion shall be accompanied by a meet and confer declaration under Section 2016.040. (including a sample order on a motion to compel) and obtaining discovery sanctions, turn to CEB's comprehensive practice guide . Sample California motion for leave to amend pleading. See C. In this instance, the order is necessary to prevent a partys serving voluminous, unfocused discovery on the eve of trial. Motion.If a deponent fails to answer a question propounded or submitted under Rules 30 or 31, or a corporation or other entity fails to make a designation under Rule 30 (b) (6) or 31 (a), or a party fails to answer an interrogatory submitted under Rule 33, or if a party, in response to a request for inspection submitted under Rule 34, fails to It appears that you have an ad-blocker running. See e.g., Weil & Brown, California Practice Guide: Civil However, the court is unlikely to issue a protective order based upon the anticipation of improper conduct during a deposition. Any Defendant, Prac. or undue burden and expense. Under California Code of Civil Procedure 2025.420, the court, for good cause shown, may make any order that justice requires to protect any party, deponent, or other natural person or organization from unwarranted annoyance, embarrassment, or oppression, or undue burden and expense. 25 The . 2030.300 Procedures For Motions To Compel Responses. 2030.270 Parties May Informally Extend Time To Respond. 2030.050. 9___________ %n san*t%ons aa%nst _____________________. The sample motion also requests sanctions. under Chapter 7 (commencing with Section 2023.010) against any party, person, or attorney who unsuccessfully makes or opposes a motion the discovery of the electronically stored information, including allocation of the Sample opposition to motion for new trial in United States District Court, Sample notice of change of address for California civil case, Sample notice of change of address for California divorce, Sample stipulation and order to appoint discovery referee in California, Sample complaint for rescission of contract in California. Consent Agreement Domestic Violence Civil Protection Order approved on Consent Agreement Dating Violence Civil Protection Order approved on In the original proceeding, I was the Petitioner Respondent. If an objection is based on a claim that the information sought is protected work product under Chapter 4 (commencing with Section 2018.010), that claim shall be expressly asserted. resolving the issues. or as soon thereafter That improper purpose was confirmed, the court . Now customize the name of a clipboard to store your clips. AND FOR MONETARY SANCTIONS IN THE These are the Local Rules of Practice in Civil Proceedings before the United States District Court for the Northern District of California. move for a protective order. 2030.040 Declaration For Additional Special Interrogatories, Option of Seeking Protective Order. Any party who is propounding or has propounded more than 35 specially prepared interrogatories to any other party shall attach to each set of those interrogatories a declaration containing substantially the following: DECLARATION FOR ADDITIONAL DISCOVERY I, __________, declare: 1. (c) If the motion for a protective order is denied in whole or in part, the court may order that the party provide or permit the discovery against which protection was sought on terms and conditions that are just. Make sure you comply with CRC 3.1110 (pdf). (b) A motion under subdivision (a) shall be accompanied by a meet and confer declaration under Section 2016.040. Business Litigation Lawyer & Personal Injury Lawyer - Nakase Law Firm A protective order may be granted to restrict any discovery method that is "unreasonably cumulative or duplicative." 8 Regardless of relevance, the statute allows courts to bar discovery that is too expensive or inconvenient, or sim-ply unnecessary.9 For example, interrogatories that request . C.C.P. At the trial or any other hearing in the action, so far as admissible under the rules of evidence, the propounding party or any party other than the responding party may use any answer or part of an answer to an interrogatory only against the responding party. Sacramento, CA 95834, Privacy Policy Cookie Policy Disclaimer Attribution. Additionally, if a party . We typically see a motion for protective order in the context of depositions. ) (Here state each factor described in Section 2030.040 that is relied on, as well as the reasons why any factor relied on is applicable to the instant lawsuit.) This sample collection of meet and confer letters for discovery in California contains over 10 sample meet and confer letters and responses to meet and confer letters including a (1) meet and confer letter for further discovery responses to interrogatories, requests for admission and requests for production of documents, (2) response to meet and Step 7: Draft and Prepare Motion for Protective Order. Others: three-year maximum unless extended by office or parties stipulate to a permanent order. Family Violence Twelve Month Protective Order. (c) The court shall impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel a response to interrogatories, unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust. 7 Also, make sure to list the nature and tile of all documents to be attached. REASONABLE GOOD FAITH ATTEMPT TO RESOLVE INFORMALLY This discovery motion, like many of the discovery motions, require you to meet and confer in good faith. The Bankruptcy Court denied the motion. It functions to bar, limit, or delay discovery on the particular information. The responding party shall then afford to the propounding party a reasonable opportunity to examine, audit, or inspect these documents and to make copies, compilations, abstracts, or summaries of them. ) Plaintiff also filed a Motion to Compel Production of Joint Defense Agreements from Defendants, (P MC: JDA) (Doc. The sample is 15 pages and include brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service. See Weil and Brown, Cal. Welcome to FindLaw's Cases & Codes, a free source of state and federal court opinions, state laws, and the United States Code. Please verify the status of the code you are researching with the state legislature or via Westlaw before relying on it for your legal needs. Guide: Civil Procedure Before Trial (TRG 2010) 8:1013. 5 Phehe`hr tmlt ),P ,##,+R+,&, Do not sell or share my personal information. MEMORANDUM IN SUPPORT OF MOTION. )" C 07-3165-CRB (PR) 1 Case 3:07-cv-03165-CRB Document 17 Filed 06/16/2008 Page 2 of 7 1 2 MOTION FOR PROTECTIVE ORDER Defendants move the above-entitled Court to enter, pursuant to Rule 26(c)(1)(B), Federal Frank W. Chen has been licensed to practice law in California since 1988. ) 2030.220 Requirement for Appropriate Response if Responding Party Does Not Have Adequate Information. (b) The propounding party shall also serve a copy of the interrogatories on all other parties who have appeared in the action. 3 3. Declaration Re Attempt To Resolve Informally. through __ of Set One, on the grounds that no declaration for additional discovery was included as Can a Motion for Protective Order be Filed after the Court has Issued its Order? Defendants' Motion for Protective Order HILL, Raynard B. v. Chudy, et al. 27 The Discovery Act provides that one of the main purposes of a protective order is to prevent a party from harassing another party with burdensome and unnecessary discovery. DISC-002 Form Interrogatories- Employment Law. (d) The court shall impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) against any party, person, or attorney who unsuccessfully makes or opposes a motion to deem binding an initial answer to an interrogatory, unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust. (b) A party may propound a supplemental interrogatory twice before the initial setting of a trial date, and, subject to the time limits on discovery proceedings and motions provided in Chapter 8 (commencing with Section 2024.010), once after the initial setting of a trial date. Submitting a proposed order is helpful because the court will likely sign it (modified or not) at the hearing, thus avoiding time-consuming and expensive post-hearing wangling about exactly what the order should say. Be prepared to discuss the facts and keep your anger and ego out of it. the sanction unjust. MOTION to strike or in the alternative, Motion for Protective Order Regarding Untimely Served Discover Requests by Whitney Information Network, Inc.. (Birken, Shawn) Download PDF Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. Weve updated our privacy policy so that we are compliant with changing global privacy regulations and to provide you with insight into the limited ways in which we use your data. Court days means Monday through 5 6 Friday, except for Court holidays. For more information about protective orders in federal court, see, Enter to open, tab to navigate, enter to select, https://content.next.westlaw.com/practical-law/document/I0f9fbe36ef0811e28578f7ccc38dcbee/Protective-Order?viewType=FullText&transitionType=Default&contextData=(sc.Default), Practice Note, Protective Orders: Overview (Federal). California's Form Interrogatories- General (DISC-001) are designed to help attorneys ascertain basic information from defendants, including insurance coverage information, with minimal controversy or work involved. If the initial set of interrogatories does not exhaust this limit, the balance may be propounded in subsequent sets. (b) If an objection is made to an interrogatory or to a part of an interrogatory, the specific ground for the objection shall be set forth clearly in the response. The defendant filed a motion to dismiss along with a motion for protective order requesting that the discovery be stayed until the court ruled on the motion to dismiss. BE PREPARED TO ARGUE FOR YOUR PROTECTIVE ORDER. This specification shall be in sufficient detail to permit the propounding party to locate and to identify, as readily as the responding party can, the documents from which the answer may be ascertained. A motion for a protective order can aid the defense by limiting the scope of the discovery process, but it can also lead to sanctions if it is deemed unwarranted or even frivolous. (3) The prejudice to the propounding party cannot be cured either by a continuance to permit further discovery or by the use of the initial answer under Section 2030.410. 1 When Do I Have to Bring a Motion to Compel Written Discovery? California Civil Discovery Charts for the Everyday Litigator Katherine L. Gallo . The court, on motion, may relieve that party from this waiver on its determination that both of the following conditions are satisfied: (1) The party has subsequently served a response that is in substantial compliance with Sections 2030.210, 2030.220, 2030.230, and 2030.240. A party may not serve interrogatories on a member of a class who is not a party representative or who has not appeared, without a court order. 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. (b) In the first paragraph of the response immediately below the title of the case, there shall appear the identity of the responding party, the set number, and the identity of the propounding party. The selected method of discovery is unduly burdensome or expensive, taking into account the needs of the case, the amount in controversy, and the importance of the issues at stake. (b) If the responding party seeks a protective order on the ground that the number of specially prepared interrogatories is unwarranted, the propounding party shall have the burden of justifying the number of these interrogatories. Orders changing the date, time, and location should obviously be made in advance. 2030.090 Option For Responding Party to Move for Protective Order. (b) The propounding party shall retain both the original of the interrogatories, with the original proof of service affixed to them, and the original of the sworn response until six months after final disposition of the action. 7. 5/21/2012 Plaintiff counsel refusing to withdraw any of the 6525requests for responses towritten discovery. Attorney who has personal knowledge of what has been happening on the eve of trial order in the context depositions... 2018 WL 4677783, at * 3 ( W.D also filed a for! 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