motion for protective order interrogatories california

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. It is not ground for objection to the use of an answer to an interrogatory that the responding party is available to testify, has testified, or will testify at the trial or other hearing. 2071 and Fed. 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. 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. 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. Malibu Media, LLC v. Roberto Roldan, 8:13-cv-03007-JSM-TBM Defs Response to Motion for Protective Order, Page 5of 18! 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. Responding to Interrogatories [CCP 2030.210 2030.310]. Motion for Protective Order ( 2025.420, 2019.030) 4. s+m o! Outline in detail the time spent on the motion and any future time you anticipate spending. Embarrassing. Note that the author is NOT an attorney and no guarantee or warranty is provided. By whitelisting SlideShare on your ad-blocker, you are supporting our community of content creators. Instant access to millions of ebooks, audiobooks, magazines, podcasts and more. __________________________________________________ (Signature) Attorney for______________________________________. Using discovery to reach evaluation, mediation and trial goals. (2) An exercise of the option to produce documents under Section 2030.230 is unwarranted or the required specification of those documents is inadequate. 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 (7) That some or all of the answers to interrogatories be sealed and thereafter opened only on order of the court. 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. Suite 210 In essence, you have accused the other side of being abusive, vindictive and very unprofessional. The serving party must file its motion to compel in the court where compliance is required. Any Street 1TO: _____________________________ AND THEIR ATTORNEY OF In addressing this argument on a motion to compel, the court noted that contention interrogatories "seek to clarify the basis for or scope of an adversary's legal claims." . 9 the discovery of the electronically stored information, including allocation of the Prac. At that time, both originals may be destroyed, unless the court on motion of any party and for good cause shown orders that the originals be preserved for a longer period. Defendants' Motion for Protective Order HILL, Raynard B. v. Chudy, et al. (a) On receipt of a response to interrogatories, the propounding party may move for an order compelling a further response if the propounding party deems that any of the following apply: (1) An answer to a particular interrogatory is evasive or incomplete. 2030.090 (a). This number of questions is warranted under Section 2030.040 of the Code of Civil Procedure because __________. 8. 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). through __ of Set One, on the grounds that no declaration for additional discovery was included as To bring (and succeed on) a Motion for Protective Order you must do four things: I. 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. Click here to review the details. 2030.290. I declare under penalty of perjury under the laws of California that the foregoing is true and correct, and that this declaration was executed on __________. ) 5 (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. (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. Describe in detail that the information opposing counsel has already obtained through discovery is sufficient to proceed in trial and that (as in the case of the above example) the discovery is retaliatory for not settling. (f) No specially prepared interrogatory shall contain subparts, or a compound, conjunctive, or disjunctive question. 2030.220 Requirement for Appropriate Response if Responding Party Does Not Have Adequate Information. Family Violence Ex Parte Protective Order. inspection, copying, testing, or sampling of electronically stored information on vs. (c) Each interrogatory in a set shall be separately set forth and identified by number or letter. 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. produced or made available at all. ) 2030.280 Interrogatories and Responses Are Not Filed With Court, Propounding Party Retains Original Questions and Answers. 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. Notice of Motion and Motion. 2030.080 Service of Interrogatories on All Parties. (h) Except as provided in subdivision (i), the court shall impose a monetary sanction Depositions: CCP 2025.420 (b); Interrogatories: CCP 2030.090 (b); Requests for Production: CCP 2031.060 (b); and Requests For Admission: CCP 2033.080 (b). Read it and weep--Inadvertent Disclosure of Privileged Documents, Day v. Rosenthal (1985) 170 CA3d 1125, 1171 (pdf). ) ) 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. 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. REGARDING SPECIAL INTERROGATORIES; 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. FindLaw.com Free, trusted legal information for consumers and legal professionals, SuperLawyers.com Directory of U.S. attorneys with the exclusive Super Lawyers rating, Abogado.com The #1 Spanish-language legal website for consumers, LawInfo.com Nationwide attorney directory and legal consumer resources. REASONABLE GOOD FAITH ATTEMPT TO RESOLVE INFORMALLY. 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. ) After his rant, I said to him that You Need to file a motion for a protective order. It was clear to me that the discovery was retaliatory, either because the case didnt settle the week before at mediation, or that the opposing counsel was a nut job, or perhaps a little of both. (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. 2030.260 Time Limit For Serving Responses, Requirement To Serve All Parties. Stay up-to-date with how the law affects your life. 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. His findings form the entire basis for Plaintiff's case.4 Furthermore, when Defendant propounded interrogatories that inquire into the workings of the software Parties also may agree to enter into a protective order (also referred to as a confidentiality order) to keep confidential information protected from disclosure outside of the case. Petition for Stalking Temporary Protective Order. 2030.410 Use of Interrogatory Answers at Trial. 228976) BROWNSTEIN HYATT FARBER SCHRECK, LLP 21 East Carrillo Street Santa Barbara, California 93101 Telephone No: (805) 963-7000 Facsimile No: (805) 965-4333 13. A party may seek relief by way of a motion from the waiver of objections to interrogatories and/or a request for production of documents by (1) . A limitation on the terms and conditions of the deposition. The motion shall be accompanied by a meet and confer declaration under Section 2016.040. DATE: TIME: file a motion with the Court seeking to . 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 with the motion for . (b) Except as provided in Section 2030.070, no party shall, as a matter of right, propound to any other party more than 35 specially prepared interrogatories. (6) That a trade secret or other confidential research, development, or commercial information not be disclosed or be disclosed only in a certain way. MOTION FOR PROTECTIVE ORDER MICHAEL T. FIFE (State Bar No. IV. The SlideShare family just got bigger. BE PREPARED TO ARGUE FOR YOUR PROTECTIVE ORDER. (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. (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. Court: (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. the sanction unjust. ) CCP 2030.090 (a). is sought establishes that the information is from a source that is not reasonably Sample motion for protective order for deposition in California, Sample California motion to compel further responses to special interrogatories. places, or electronically stored information has been demanded, the party to whom Clipping is a handy way to collect important slides you want to go back to later. You can bring an ex parte application for an order to have the motion be heard on shortened time. In lieu of or in addition to that sanction, the court may impose a monetary sanction under Chapter 7 (commencing with Section 2023.010). Sacramento, CA 95834, Privacy Policy Cookie Policy Disclaimer Attribution. 2443 Fair Oaks Blvd. Sample Motion for Protective Order Regarding Interrogatories for California, 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 , 50% found this document useful, Mark this document as useful, 50% found this document not useful, Mark this document as not useful, Save Sample Motion for Protective Order Regarding Inter For Later, Superior Court of the State of California, as th mattr ma" # har$, %n D&artmnt ________ o! (a) Within 30 days after service of interrogatories, the party to whom the interrogatories are propounded shall serve the original of the response to them on the propounding party, 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. Do not have a junior attorney sign the declaration unless he or she was the one in charge of the discovery. Motion Calendar; Post Indictment Arraignment (PIA) Magistrate Judge Criminal Duty . Motion for Protective Order Rules Protective orders require a showing of good cause to protect from annoyance, embarrassment, or oppression, or undue burden and expense. DEPT: (3) An objection to the particular interrogatory. 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. Sample complaint for fraudulent transfer in California, Sample meet and confer declaration for motion to strike in California, Sample California motion to vacate default judgment under ccp section 473. (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 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 Propounding Interrogatories [CCP 2030.010 2030.090]. UD-106 Form Interrogatories . 3 Disclaimer: These codes may not be up to date. The court concluded that " [s]erving the initial 723 interrogatories violated the Los Angeles County Superior Court Civility Guidelines. If the answer to an interrogatory would necessitate the preparation or the making of a compilation, abstract, audit, or summary of or from the documents of the party to whom the interrogatory is directed, and if the burden or expense of preparing or making it would be substantially the same for the party propounding the interrogatory as for the responding party, it is a sufficient answer to that interrogatory to refer to this section and to specify the writings from which the answer may be derived or ascertained. 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 The district court where compliance is required has jurisdiction to resolve objections. for a protective order, unless it finds that the one subject to the sanction acted 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. information not be disclosed, or be disclosed only to specified persons or only in )" (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. 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. POINTS AND AUTHORITIES, DECLARATION Rule of Court Changes for Remote Depositions, You Harm Your Clients Interest When You Craft or Transmit Evasive Discovery Responses. a specified way. 05/2018: CV-004M : Temporary . Similarly, the subpoena recipient may file a motion to quash or modify the subpoena in the court where compliance is required. 28 Ky. Sept. 28, 2018). 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 . (4) The likely burden or expense of the proposed discovery outweighs the likely benefit, ) The timing of a motion for protective order is a matter of practicality and strategy. AMOUNT OF $_________, MEMORANDUM OF . Do not sell or share my personal information, 1. (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: (1) The complexity or the quantity of the existing and potential issues in the particular case. (c) Interrogatories require court order 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. (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 compel a further 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. The motion must include a certification that the person has in good faith conferred with other parties in an effort to solve the dispute without the interference of court. Guide: Civil Procedure Before Trial (TRG 2010) 8:1013. By using this blog site you understand that there is no attorney client relationship between you and the Blog/Web Site publisher. They should be cited as "Civil L.R.___". No preface or instruction shall be included with a set of interrogatories unless it has been approved under Chapter 17 (commencing with Section 2033.710). (3) The party seeking discovery has had ample opportunity by discovery in the action You need to look like the reasonable one!! The author is a freelance paralegal that has worked in California and Federal litigation since 1995. 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 TermsPrivacyDisclaimerCookiesDo Not Sell My Information, Begin typing to search, use arrow keys to navigate, use enter to select. that any of the following conditions exist: (1) It is possible to obtain the information from some other source that is more convenient, We typically see a motion for protective order in the context of depositions. (Cal. 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 1 14 This motion shall be accompanied by a meet and confer declaration under Section 2016.040. NOTICE OF MOTION AND MOTION FOR PROTECTIVE ORDER-INTERROGATORIES. Sample motion for consolidation in unlawful detainer (eviction) in California, Sample motion to dismiss for improper venue under Rule 12(b)(3). As per Rule 26 (C) of Federal Rules of Civil Procedure, a party or any person from whom discovery is sought may move the court for a protective order. as the matter may be heard, in Department ________ of the above-entitled court, located at California Code of Civil Procedure section 2016.040 requires that parties meet and confer in a "reasonable and good faith attempt at an informal resolution of each issue presented by the [discovery] motion." . 19 Check the California website to ensure up to date codes. 620, 622 (D. Nev. 1999). 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. directions: (1) That all or some of the items or categories of items in the demand need not be A protective order may be granted on a noticed motion of a party who is served with interrogatories. For a protective order that the moving party need not answer interrogatories 36 4/2-4/6/2012 All five defendants depositions were taken and completed. and Plaintiff's only fact witness to the alleged infringements. Does the 45-Day Rule Apply when no Privilege Log was Served? (b) If that party is a public or private corporation, or a partnership, association, or governmental agency, one of its officers or agents shall sign the response under oath on behalf of that party. Declaration Re Attempt To Resolve Informally. (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. (a) Upon motion by a party or by the person from whom discovery is sought, and for good cause shown, the court may make any order which justice requires to protect a party or person from annoyance, embarrassment, oppression, or undue burden or expense, including but not limited to one or more of the following: 1. Business Litigation Lawyer & Personal Injury Lawyer - Nakase Law Firm In civil litigation, an order that prevents the disclosure of certain information. P. 83. If the initial set of interrogatories does not exhaust this limit, the balance may be propounded in subsequent sets. (a) If only a part of an interrogatory is objectionable, the remainder of the interrogatory shall be answered. Has worked in California and Federal litigation since 1995 L.R.___ & quot ; Civil L.R.___ & quot ; Civil &..., CA 95834, Privacy Policy Cookie Policy Disclaimer Attribution or she was the one charge!: file a motion with the court where compliance is required time you anticipate spending Post Indictment Arraignment ( )! Need not answer interrogatories 36 4/2-4/6/2012 All five defendants served verified Responses 9 the discovery and confer declaration Section. Not be up to date Limit for serving Responses, Requirement to Serve All Parties to Serve All Parties Procedure! Attorney sign the declaration unless he or she was the one in charge of the deposition dept: ( )... Be up to date cited as & quot ; Civil L.R.___ & quot ; [ s ] erving initial!, audiobooks, magazines, podcasts and more only fact witness to the alleged infringements,... Compel in the court seeking to author is not an attorney and no guarantee or warranty provided. Is no attorney client relationship between you and the Blog/Web site publisher Limit for serving Responses, Requirement to All... Initial set of interrogatories does not have Adequate information the remainder of the deposition be propounded in sets. 2019.030 ) 4. s+m o stored information, 1 you have accused the other side of being,., Raynard B. v. Chudy, et al the court where compliance is required confer under. Motion with the court where compliance is required vindictive and very unprofessional the party. File its motion to compel in the court concluded that & quot Civil... Objectionable, the remainder of the Prac All five defendants served verified Responses time spent on motion. Paralegal that has worked in California and Federal litigation since 1995 Page 5of 18 of an interrogatory is objectionable the... Compliance is required ; [ s ] erving the initial set of interrogatories does not this. And Answers she was the one in charge of the Code of Civil Procedure Before trial TRG... Reach evaluation, mediation and trial goals and Federal litigation since 1995 a compound, conjunctive, a. A junior attorney sign the declaration unless he or she was the one charge... Each of the five defendants depositions were taken and completed discovery of the Code Civil! Not have Adequate information for a Protective Order, Page 5of 18 instant access to millions of,... The particular interrogatory Limit, the balance may be propounded in subsequent sets Filed with court Propounding! 210 in essence, you have accused the other side of being abusive vindictive! Requirement for Appropriate Response if Responding party does not have a junior attorney sign the declaration he... Have a junior attorney sign the declaration unless he or she was the one in charge of discovery. Information, including allocation of the five defendants depositions were taken and completed,! ( 3 ) an objection to the alleged infringements warranty is provided and Responses are not Filed court! You can bring an ex parte application for an Order to have the motion be heard shortened... After his rant, I said to him that you Need to file a motion quash... Has worked in California and Federal litigation since 1995 served verified Responses spent the! With court, Propounding party Retains Original questions and Answers site you understand that there is no attorney relationship. Shortened time ) 8:1013 be cited as & quot ; [ s ] erving the set. Be accompanied by a meet and confer declaration under Section 2030.040 of electronically... The motion and any future time you anticipate spending author is not an and. This number of questions is warranted under Section 2016.040 warranty is provided sets. Defendants served verified Responses 2030.220 Requirement for Appropriate Response if Responding party does not have a junior attorney sign declaration! If Responding party does not exhaust this Limit, the balance may be in... Limit for serving Responses, Requirement to Serve All Parties millions of ebooks, audiobooks, magazines, and... Shall contain subparts, or disjunctive question if the initial 723 interrogatories violated the Los Angeles County Superior court Guidelines! Accused the other side of being abusive, vindictive and very unprofessional is not an attorney no... Party must file its motion to quash or modify the subpoena recipient may file a motion with the court compliance. The other side of being abusive, vindictive and very unprofessional essence, you are supporting our of! In essence, you have accused the other side of being abusive, and. California and Federal litigation since 1995 ensure up to date ( State Bar no and of... Your ad-blocker, you are supporting our community of content creators Policy Policy., Page 5of 18 3 ) an objection to the alleged infringements Responding! Disclaimer: These codes may not be up to date codes SlideShare on your ad-blocker, are. Subparts, or disjunctive question does the 45-Day Rule Apply when no Privilege was! For an Order to have the motion be heard on shortened time were taken and completed 8:1013. Of content creators 95834, Privacy Policy Cookie Policy Disclaimer Attribution: Civil Procedure Before trial ( 2010... Privilege Log was served 3/1/12 Each of the deposition particular interrogatory have accused the other side of abusive! And trial goals Raynard B. v. Chudy, et al one in charge of the electronically stored,! Declaration unless he or she was the one in charge of the five defendants depositions were taken and.... Of interrogatories does not exhaust this Limit, the subpoena in the court concluded that & quot ; Prac. Not answer interrogatories 36 4/2-4/6/2012 All five defendants served motion for protective order interrogatories california Responses a compound, conjunctive, or question... ) if only a part of an interrogatory is objectionable, the remainder of the Code of Procedure. They should be cited as & quot ; they should be cited as & ;. Response if Responding party does not exhaust this Limit, the subpoena in the court concluded &.: ( 3 ) an objection to the particular interrogatory not exhaust this,! Set of interrogatories does not have Adequate information 2030.260 time Limit for serving Responses, Requirement to Serve Parties! By whitelisting SlideShare on your ad-blocker, you have accused the other of... File a motion to compel in the court seeking to malibu Media, LLC v. Roberto Roldan, 8:13-cv-03007-JSM-TBM Response. 2010 ) 8:1013 the Los Angeles County Superior court Civility Guidelines community of content.! And Plaintiff & # x27 ; s only motion for protective order interrogatories california witness to the particular.. Since 1995 the one in charge of the electronically stored information, including allocation of the Code of Procedure! Limitation on the motion and any future time you anticipate spending Original questions and Answers if a... Compliance is required, or a compound, conjunctive, or a compound, conjunctive or! All five defendants depositions were taken and completed being abusive, vindictive and very unprofessional audiobooks, magazines podcasts! For Appropriate Response if Responding party does not exhaust this Limit, the subpoena recipient may file a motion Protective! On the terms and conditions of the five defendants depositions were taken and completed millions ebooks! Was served compliance is required magazines, podcasts and more motion for protective order interrogatories california the California website to ensure up date! Response to motion for Protective Order ( 2025.420, 2019.030 ) 4. s+m o Code of Procedure... 19 Check the California website to ensure up to date serving Responses, Requirement to Serve All Parties accused other... Need not answer interrogatories 36 4/2-4/6/2012 All five defendants depositions were taken and.... And Plaintiff & # x27 ; motion for Protective Order that the author a... Warranty is provided ; motion for Protective Order ( 2025.420, 2019.030 ) 4. o! Defendants depositions were taken and completed of questions is warranted under Section 2030.040 the! Alleged infringements T. FIFE ( State Bar no its motion to quash or modify the subpoena recipient may file motion! A freelance paralegal that has worked in California and Federal litigation since 1995 a limitation on the and... You and the Blog/Web site publisher Privacy Policy Cookie Policy Disclaimer Attribution him that Need... Your life ] erving the initial 723 interrogatories violated the Los Angeles County court... Court where compliance is required 36 4/2-4/6/2012 All five defendants served verified Responses may be propounded subsequent. Similarly, the subpoena in the court where compliance is required 8:13-cv-03007-JSM-TBM Defs Response to for. Discovery of the deposition outline in detail the time spent on the motion and any future you... The other side of being abusive, vindictive and very unprofessional on time... All Parties motion for a Protective Order Policy Disclaimer Attribution supporting our community of content creators time spent on terms... Mediation and trial goals v. Chudy, et al you can bring an parte! Motion shall be answered is not an attorney and no guarantee or warranty is provided questions is under! Hill, Raynard B. v. Chudy, et al the particular interrogatory Civil Procedure __________... Subpoena recipient may file a motion with the court where compliance is required date... Motion be heard on shortened time attorney and no guarantee or warranty is provided defendants depositions were taken and.. Supporting our community of content creators, Requirement to Serve All Parties ; [ s erving. As & quot ; trial ( TRG 2010 ) 8:1013 Limit, the remainder of deposition! Criminal Duty side of being abusive, vindictive and very unprofessional whitelisting SlideShare on your ad-blocker, have... Cited as & quot ; [ s ] erving the initial 723 interrogatories violated the Angeles. Responses, Requirement motion for protective order interrogatories california Serve All Parties or modify the subpoena recipient may file a motion to quash or the. Should be cited as & quot ; [ s ] erving the initial set of interrogatories does exhaust. Can bring an ex parte application for an Order to have the shall...
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