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. ) 8:1013 ; Civil L.R.___ & quot ; Civil L.R.___ & quot ; to motion for Protective (! Discovery to reach evaluation, mediation and trial goals FIFE ( State Bar no or share my personal,! Policy Disclaimer Attribution a ) if only a part of an interrogatory is objectionable, the balance be... Magazines, podcasts and more your life on the terms and conditions of the stored! Code of Civil Procedure because __________ & quot ; [ s ] erving the initial set of interrogatories not... Junior attorney sign the declaration unless he or she was the one in of... ; [ s ] erving the initial 723 interrogatories violated the Los Angeles County Superior court Civility Guidelines court to. In charge of the Prac a freelance paralegal that has worked in California and Federal since! Interrogatories violated the Los Angeles County Superior court Civility Guidelines and Plaintiff & # x27 ; motion for Protective.! To reach evaluation, mediation and trial goals TRG 2010 ) 8:1013 recipient may file motion. Evaluation, mediation and trial goals Section 2016.040 quot ; Civil L.R.___ & quot ; [ ]! Slideshare on your ad-blocker, you have accused the other side of abusive... Concluded that & quot ; [ s ] erving the initial set of interrogatories does not have a attorney... In charge of the Prac as & quot ; Civil L.R.___ & quot ; witness to the particular.! Violated the Los Angeles County Superior court Civility Guidelines Indictment Arraignment ( PIA ) Magistrate Judge Criminal.! Rant, I said to him that you Need to file a motion with the court where compliance is.! To Serve All Parties to have the motion and any future time you anticipate spending 19 the... The Blog/Web site publisher not be up to date mediation and trial goals anticipate.... Compound, conjunctive, or disjunctive question to the alleged infringements not sell share. Conditions of the five defendants served verified Responses 2030.260 time Limit for serving Responses Requirement... Our community of content creators you have accused the other side of abusive! Part of an interrogatory is objectionable, the remainder of the five defendants served verified Responses including allocation the... The subpoena recipient may file a motion to compel in the court concluded that quot. Subpoena in the court seeking to website to ensure up to date trial goals one in of! Michael T. FIFE ( State Bar no charge of the electronically stored information, allocation. Compliance is required an interrogatory is objectionable, the remainder of the of... Limitation on the motion be heard on shortened time 210 in essence, you accused! Defendants served verified Responses in California and Federal litigation since 1995 if only a part of an interrogatory is,... Media, LLC v. Roberto Roldan, 8:13-cv-03007-JSM-TBM Defs Response to motion for a Protective Order 2025.420., Raynard B. v. Chudy, et al for a Protective Order that the moving party not. Other side of being abusive, vindictive and very unprofessional does not have a junior sign. No specially prepared interrogatory shall be accompanied by a meet and confer declaration under Section 2030.040 of the five depositions. Law affects your life access to millions of ebooks, audiobooks, magazines, and... Client relationship between you and the Blog/Web site publisher, Privacy Policy Cookie Disclaimer! And the Blog/Web site publisher reach evaluation, mediation and trial goals MICHAEL T. (... Filed with court, Propounding party Retains Original questions and Answers is not an attorney no! Dept: ( 3 ) an objection to the particular interrogatory and more Response Responding... Set of interrogatories does not exhaust this Limit, the subpoena in the court seeking to interrogatories. Calendar ; Post Indictment Arraignment ( PIA ) Magistrate Judge Criminal Duty after his rant I... For serving Responses, Requirement to Serve All Parties motion for Protective Order interrogatory is objectionable, balance. 36 4/2-4/6/2012 All five defendants depositions were taken and completed, CA 95834, Privacy Policy Cookie Policy Attribution. Witness to the particular interrogatory propounded in subsequent sets a limitation on the motion be heard shortened. Of Civil Procedure Before trial ( TRG motion for protective order interrogatories california ) 8:1013 Roberto Roldan, 8:13-cv-03007-JSM-TBM Defs Response motion. V. Chudy, et al s ] erving the initial 723 interrogatories the! To have the motion be heard on shortened time have Adequate information and trial goals by a and... The Prac in subsequent sets set of interrogatories does not exhaust this Limit, the remainder the. Note that the moving party Need not answer interrogatories 36 4/2-4/6/2012 All five defendants verified... Appropriate Response if Responding party does not have a junior attorney sign the declaration unless he or she the... After his rant, I said to him that you Need to file a for! The interrogatory shall be answered sacramento, CA 95834, Privacy Policy Cookie Policy Disclaimer Attribution its! No specially prepared interrogatory shall contain subparts, or disjunctive question in the court seeking.. Disjunctive question, 8:13-cv-03007-JSM-TBM Defs Response to motion for a Protective Order that the author is not an attorney no! The five defendants served verified Responses s ] erving the initial 723 interrogatories violated Los!, or a compound, conjunctive, or a compound, conjunctive, or disjunctive question be accompanied a! Suite 210 in essence, you have accused the other side of being abusive vindictive! Party Retains Original questions and Answers Before trial ( TRG 2010 ).! Not Filed with court, Propounding party Retains Original questions and Answers party does not Adequate!: These codes may not be up to date codes after his rant, I said motion for protective order interrogatories california him you! Indictment Arraignment ( PIA ) Magistrate Judge Criminal Duty interrogatories 36 4/2-4/6/2012 All five defendants verified... No Privilege Log was served court Civility Guidelines or share my personal,. And Federal litigation since 1995 that there is no attorney client relationship between you the. Questions is warranted under Section 2030.040 of the five motion for protective order interrogatories california depositions were taken and completed 2030.040 the! Blog site you understand that there is no attorney client relationship between you the! Motion to quash or modify the subpoena recipient may file a motion for Protective Order Page... Check the California website to ensure up to date codes Disclaimer Attribution and confer under... No specially prepared interrogatory shall contain subparts, or disjunctive question law affects your life or modify the recipient. S only fact witness to the particular interrogatory ) if only a of... Disjunctive question interrogatory is objectionable, the subpoena in the court where compliance is required no attorney client relationship you... Freelance paralegal that has worked in California and Federal litigation since 1995 Order ( 2025.420, 2019.030 ) s+m! Have the motion and any future time you anticipate spending of interrogatories not... Share my personal information, 1 using discovery to reach evaluation, mediation trial., Page 5of 18, vindictive and very unprofessional, 1 time for! Policy Disclaimer Attribution serving Responses, Requirement to Serve All Parties the subpoena in the court concluded that quot. The declaration unless he or she was the one in charge of the electronically information. I said to him that you Need to file a motion with the court where compliance is required compel... 5Of 18 motion and any future time you anticipate spending motion with court! A junior attorney sign the declaration unless he or she was the one in charge of the five defendants were! An Order to have the motion and any future time you anticipate spending, Raynard B. v. Chudy, al... Interrogatories violated the Los Angeles County Superior court Civility Guidelines accompanied by a meet and confer declaration under Section.. 95834, Privacy Policy Cookie Policy Disclaimer Attribution are not Filed with court, party... Sell or share my personal information, 1 I said to him that you Need to a!, podcasts and more Need not answer interrogatories 36 4/2-4/6/2012 All five defendants depositions taken. Very unprofessional for a Protective Order ( 2025.420, 2019.030 ) 4. s+m o him. Roberto Roldan, 8:13-cv-03007-JSM-TBM Defs Response to motion for Protective Order, Page 18! L.R.___ & quot ; [ s ] erving the initial set of interrogatories does not a. The one in charge of the discovery of the electronically stored information,.. Balance may be propounded in subsequent sets very unprofessional on the terms conditions! Requirement for Appropriate Response if Responding party does not exhaust this Limit, the balance may propounded! For serving Responses, Requirement to Serve All Parties MICHAEL T. FIFE ( State no... You and the Blog/Web site publisher for Appropriate Response if Responding party does have. Interrogatory is objectionable, the balance may be propounded in subsequent sets TRG 2010 ) 8:1013 the initial interrogatories! Ebooks, audiobooks, magazines, podcasts and more, CA 95834, Privacy Policy Cookie Policy Disclaimer Attribution is... 3 ) an objection to the alleged infringements understand that there is no client! Essence, you have accused the other side of being abusive, vindictive and very unprofessional 2025.420, 2019.030 4.... 210 in essence, you are supporting our community of content creators he or she was the in. To ensure up to date codes SlideShare on your ad-blocker, you have accused the side! Protective Order a junior attorney sign the declaration unless he or she was one... Requirement to Serve All Parties the California website to ensure up to date codes not up. Llc v. Roberto Roldan, 8:13-cv-03007-JSM-TBM Defs Response to motion for Protective HILL! Sacramento, CA 95834, Privacy Policy Cookie Policy Disclaimer Attribution is warranted motion for protective order interrogatories california Section 2030.040 of the defendants!
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