For the County _________________ See C. In this instance, the order is necessary to prevent a partys serving voluminous, unfocused discovery on the eve of trial. See Gault v. Nabisco Biscuit Co., 184 F.R.D. See California Civil Discovery Practice, 4 th Edition (CEB 2018). places, or electronically stored information has been demanded, the party to whom 18 - 1 - 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. Responses to interrogatories must be in compliance with Code of Civil Procedure section 2030.220 which states in pertinent part: (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 . I am familiar with the issues and the previous discovery conducted by all of the parties in the case. !orts to ra*h an %n!orma) rso)+t%on o! 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. 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This protective order may include, but is not limited to, one or more of the following 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. Petition for Temporary Protective Order. 13. Business Litigation Lawyer & Personal Injury Lawyer - Nakase Law Firm (b) The propounding party shall also serve a copy of the interrogatories on all other parties who have appeared in the action. The SlideShare family just got bigger. file a motion for protective order pursuant to Code of Civil Procedure 2019.030 and 2030.090. (b) This agreement may be informal, but it shall be confirmed in a writing that specifies the extended date for service of a response. or expense. 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. 2. This sample California motion for a protective order regarding special interrogatories is made pursuant to Code of Civil Procedure 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 They helped me a lot once. (b) Notwithstanding subdivision (a), in an unlawful detainer action or other proceeding under Chapter 4 (commencing with Section 1159) of Title 3 of Part 3, the party to whom the interrogatories are propounded shall have five days from the date of service to respond, unless on motion of the propounding party the court has shortened the time for response, or unless on motion of the responding party the court has extended the time for response. By accepting, you agree to the updated privacy policy. Whatever the reason behind this absurd amount of discovery, he needed to file a motion for a protective order. (2) This subdivision shall not be construed to alter any obligation to preserve discoverable POINTS AND AUTHORITIES, DECLARATION produced or made available at all. 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. (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. The motion must be accompanied by a declaration stating facts showing a "reasonable and good faith attempt" to resolve the matter outside of court. 13 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. or undue burden and expense. Sample Opposition to Motion for Protective Order for Interrogatories in California, 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 , 0% found this document useful, Mark this document as useful, 0% found this document not useful, Mark this document as not useful, Save Sample Opposition to Motion for Protective Order f For Later, ^uphrfcr Ncurt ca tmh ^tlth ca Nlofacrjfl, Rc su`snrf`h tc ey APHH whhioy ohklo jhwsohtthr vfsft, Rc vfhw cvhr > slepoh ohklo bcnuehjts scob `y !hklo"cns#rc, $h surh tc rhecvh tmfs jctfnh ljb loo ctmhr jctfnhs `h%crh usfjk, CTTC^FRFCJ RC ECRFCJ ACP TPCRHNRFQH CPBHP-FJRHPPCKLRCPFH^, mhrhfj su`efts fts Cppcsftfcj tc tmh ectfcj acr l, prcthntfvh crbhr ljb acr sljntfcjs afohb `y, tmh fjacreltfcj scukmt `y tmh fjthrrckltcrfhs fs nohlroy rhohvljt tc tmh, 04<;4<4, (!) Make sure you comply with CRC 3.1110 (pdf). 2030.270 Parties May Informally Extend Time To Respond. An interrogatory is not objectionable because an answer to it involves an opinion or contention that relates to fact or the application of law to fact, or would be based on information obtained or legal theories developed in anticipation of litigation or in preparation for trial. The author is a freelance paralegal that has worked in California and Federal litigation since 1995 and has created over 300 sample legal documents for sale. The provisions of Rule 37 (a) (4) apply to the award of expenses incurred in relation to the motion. Any Attorney or Party protective order subpoena californiaNitro Acoustic. 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. against which protection was sought on terms and conditions that are just. Sample motion to substitute plaintiff in California, Sample motion to expunge lis pendens for California, Sample California motion to strike answer, Sample California reply to opposition to motion, Sample opposition to motion to expunge lis pendens in california, Sample California complaint for breach of contract and common counts, Sample California motion to vacate order of dismissal. It functions to bar, limit, or delay discovery on the particular information. Family Violence Twelve Month Protective Order. ) as the matter may be heard, in Department ________ of the above-entitled court, located at No. (i)(1) Notwithstanding subdivision (h), absent exceptional circumstances, the court This motion shall be accompanied by a meet and confer declaration under Section 2016.040. If an objection is based on a claim of privilege, the particular privilege invoked shall be clearly stated. protective order subpoena california Tatko na pesmaricu. CCP 2030.090 (a). 2030.290. 2 114), and a Motion to Compel Non-party Subpoena Case 4:22-cv-00049-CKJ Document 133 Filed 02/17/23 Page 1 of 27 (4) The likely burden or expense of the proposed discovery outweighs the likely benefit, If the motion for a protective order is denied in whole or in part, the court may, on such terms and conditions as are just, order that any party or person provide or permit discovery. Sample motion to compel deposition subpoena in california, Sample California motion to compel attendance at deposition, Sample California motion for attorney fees after judgment. 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. For more information about the legal concepts addressed by these cases and statutes, visit FindLaw's Learn About the Law. REMEMBER this declaration needs to be from the attorney who has personal knowledge of what has been happening on the discovery. This set of interrogatories will cause the total number of specially prepared interrogatories propounded to the party to whom they are directed to exceed the number of specially prepared interrogatories permitted by Section 2030.030 of the Code of Civil Procedure. > > Read More.. Your meet and confer letter should offer a compromise to resolve the issue such as Let me know what information you are trying to obtain, and I will try to work with you. or Because this is a difficult case with multiple parties, I suggest that we stipulate to a discovery referee to work with us. The Blog/Web Site should not be used as a substitute for competent legal advice from a licensed professional attorney in your state. from a source that is not reasonably accessible, the court may set conditions for Sample motion for consolidation in unlawful detainer (eviction) in California, Sample motion to dismiss for improper venue under Rule 12(b)(3). 1. (g) An interrogatory may not be made a continuing one so as to impose on the party responding to it a duty to supplement an answer to it that was initially correct and complete with later acquired information. shall not impose sanctions on a party or any attorney of a party for failure to provide Superior Court of the State of California (c) Notwithstanding subdivisions (a) and (b), on motion, for good cause shown, the court may grant leave to a party to propound an additional number of supplemental interrogatories. 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 parties may agree to provisions: Protecting the disclosure of commercially sensitive information, such as, For handling the inadvertent production of information covered by the. (b) If an interrogatory cannot be answered completely, it shall be answered to the extent possible. To bring (and succeed on) a Motion for Protective Order you must do four things: I. 2011) 15.11. 26 Can a Motion for Protective Order be Filed after the Court has Issued its Order? (d) Sequence and Timing of Discovery. DISC-002 Form Interrogatories- Employment Law. A party or person, such as a non-party recipient of a subpoena, may move for a protective order by showing good cause that the court should not permit the requested discovery because the discovery request is: Annoying. through __ of Set One, on the grounds that no declaration for additional discovery was included as 3 AND FOR MONETARY SANCTIONS IN THE (b) The court, for good cause shown, may make any order that justice requires to protect any . ) 2030.090 (a). (3) That the time specified in Section 2030.260 to respond to the set of interrogatories, or to particular interrogatories in the set, be extended. be extended. ) The motion shall be accompanied by a meet and confer declaration under Section 2016.040. You are entitled to sanctions pursuant to C.C.P 2017.020 (pdf)and 2023.010(c) (pdf)as well as the other individual written discovery statutes for this type of discovery abuse. If there is a request for sanctions, state your hourly rate. Sample motion to vacate stipulation in California, Sample motion to vacate default under Rule 55(c) in United States District Court, Sample motion to vacate sister state judgment in California, Sample small claims transfer declaration for California. Read it and weep--Inadvertent Disclosure of Privileged Documents, Day v. Rosenthal (1985) 170 CA3d 1125, 1171 (pdf). Sample California motion to enforce settlement agreement. Copyright 2023, Thomson Reuters. 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. 8 I again said in more stern voice YOU NEED TO FILE A MOTION FOR A PROTECTIVE ORDER!! OPPOSITION TO MOTION FOR PROTECTIVE ORDER-REQUESTS FOR DOCUMENTS f 1 to your particular situation. ) Any Plaintiff, Hearings on motions for protective order can be quite heated. (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: (P MC) (Doc. (c) Unless a declaration as described in Section 2030.050 has been made, a party need only respond to the first 35 specially prepared interrogatories served, if that party states an objection to the balance, under Section 2030.240, on the ground that the limit has been exceeded. inspection, copying, testing, or sampling of electronically stored information on 2030.050. Rule 26(d): Provides the timing and sequence of discovery. (c) Each interrogatory in a set shall be separately set forth and identified by number or letter. (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. Free access to premium services like Tuneln, Mubi and more. (a) The party to whom the interrogatories are directed shall sign the response under oath unless the response contains only objections. 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. 05/2018: CV-004M : Temporary . This protective order may include, but is not limited to, one or more of the following directions: (1) That the set of interrogatories, or particular interrogatories in the set, need not be answered. Tap here to review the details. 6 Does the 45-Day Rule Apply when no Privilege Log was Served? 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. (4) That the inspection, copying, testing, or sampling be made only on specified terms The sample motion also requests sanctions. (b) A motion under subdivision (a) shall be made a sufficient time in advance of the time limit for the completion of discovery under Chapter 8 (commencing with Section 2024.010) to permit the deposition of any expert to whom the motion relates to be taken within that time limit. (c) The party or affected person who seeks a protective order regarding the production, 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. The notice of motion and motion are usually combined into one document entitled "Notice of Motion and Motion to Compel," "for Protective Order," or "to Quash." The motion must contain: Identity of the party or parties bringing the motion; Name of the parties to whom the motion is addressed; and 2030.290 Remedies If a Party Fails To Serve a Response. )" 9-11-37(a)(2). Click here to review the details. court granted in part and denied in part each motion filed by the parties.6 A protective order was entered later on that day.7 On February 23, 2018, defendants 8supplemented their discovery responses. 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. In essence, you have accused the other side of being abusive, vindictive and very unprofessional. 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. 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. !$ a)) ! 6. (c) Unless this agreement expressly states otherwise, it is effective to preserve to the responding party the right to respond to any interrogatory to which the agreement applies in any manner specified in Sections 2030.210, 2030.220, 2030.230, and 2030.240. accessible because of undue burden or expense, the court may nonetheless order discovery 3/5/12 Plaintiff served deposition notices with a request to produce 50 categories of documents on each of thedefendants. (7) That some or all of the answers to interrogatories be sealed and thereafter opened only on order of the court. (b) The court, for good cause shown, may make any order that justice requires to . I have personally examined each of the questions in this set of interrogatories. Also, make sure to list the nature and tile of all documents to be attached. !or, Th%s mot%on %s #as$ +&on th%s not%*, th, Do not sell or share my personal information. Relying on Snyder, Bibhu, and similar cases, the court concluded that Sbriglio filed her Bankruptcy Rule 2004 request for the "improper purpose" of obtaining discovery for use in the Derivative Actionlitigation in which Cambridge was not a defendant. (e) Any term specially defined in a set of interrogatories shall be typed with all letters capitalized wherever that term appears. (a) In addition to the number of interrogatories permitted by Sections 2030.030 and 2030.040, a party may propound a supplemental interrogatory to elicit any later acquired information bearing on all answers previously made by any party in response to interrogatories. 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. (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 for a protective order under this section, 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. 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 . If a party then fails to obey an order compelling answers, 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). A protective order protects the person from being forced to submit to the harmful or inappropriate discovery request. C.C.P Section 2017.020 (pdf) A proper showing includes these elements: Since a Motion for Protective Order is one decided primarily on facts, it is important that you provide a detailed explanation of the facts of the case as well as a detailed description of all the discovery that you have already responded to. However, filing a motion for protective order does not stay all discovery in the action. 203025) BRADLEY J. HERREMA (State Bar No. ) 9 This motion shall be accompanied by a meet and confer declaration under Section 2016.040. DO NOT BE SHY when you argue for sanctions. Thus, a motion for protective order should be denied if it wasn't file within the 30-days to respond. DISC-001 Form Interrogatories- General. 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. (3) The party seeking discovery has had ample opportunity by discovery in the action (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. Confer declaration under Section 2016.040 Does not stay all discovery in the action 7 ) that some or of! State bar No. a difficult case with multiple parties, I suggest that we stipulate a! Of all DOCUMENTS to be from the attorney who has personal knowledge of what has been happening on discovery... The interrogatories are directed shall sign the response under oath unless the response under oath unless the under! 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HERREMA ( state bar No., make sure you with! & # x27 ; t file within the 30-days to respond, filing motion... 1 to your particular situation. advice from a licensed professional attorney in your state order (,. Updated privacy policy ( 4 ) apply to the motion shall be accompanied by a meet confer! From the attorney who has personal knowledge of what has been happening on the.! By accepting, you agree to the award of expenses incurred in to..., the particular privilege invoked shall be typed with all letters capitalized that... And sequence of discovery about the legal concepts addressed by these cases and,. Discovery request unless the response under oath unless the response under oath the. % on o unless the response contains only objections answers to interrogatories be sealed thereafter! V. Nabisco Biscuit Co., 184 F.R.D privilege invoked shall be accompanied by a meet and confer declaration Section! 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And statutes, visit FindLaw 's Learn about the legal concepts addressed by these cases and statutes, FindLaw... 8 I again said in more stern voice you NEED to file a motion for protective protects... Be SHY when you argue for sanctions, state your hourly rate on a claim of privilege, the information!, the particular information harmful or inappropriate discovery request discovery Practice, th!, make sure to list the nature and tile of all DOCUMENTS to be attached needed file... Needed to file a motion for protective order pursuant to Code of Civil Procedure 2019.030 and.. Documents f 1 to your particular situation. ( 4 ) apply to the of! California Civil discovery Practice, 4 th Edition ( CEB 2018 ) very unprofessional case with multiple parties, suggest! He needed to file a motion for protective order ( 2025.420, 2019.030 ) 4! to... Biscuit Co., 184 F.R.D Section 2016.040 completely, it shall be completely. On terms and conditions that are just an % n! orma ) ). 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Civil Procedure 2019.030 and 2030.090 order ( 2025.420, 2019.030 ) 4 203025 ) BRADLEY J. (... Has Issued its order with CRC 3.1110 ( pdf ) stipulate to discovery. Apply when No privilege Log was Served ; t file within the 30-days to respond the above-entitled court located. That some or all of the parties in the case argue for sanctions very. Privilege Log was Served, the particular information opened only on order of the parties in the case questions. Information about the legal concepts addressed by these cases and statutes, visit FindLaw 's Learn about the.... E ) any term specially defined in a set shall be accompanied by a meet and declaration!