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    Sample Opposition To Motion For Protective Order For Interrogatories in California

    Uploaded by

    Stan Burman
    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. 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. 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. 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. Note that the author is NOT an attorney and no guarantee or warranty is provided.

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    © All Rights Reserved
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    Sample Opposition To Motion For Protective Order For Interrogatories in California

    Uploaded by

    Stan Burman
    1K views3 pages
    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. 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. 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. 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. Note that the author is NOT an attorney and no guarantee or warranty is provided.

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    Sample Opposition to Motion for Protective Order for Interrogatories in California

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    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. 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. 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. 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. Note that the author is NOT an attorney and no guarantee or warranty is provided.

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
    1K views3 pages

    Sample Opposition To Motion For Protective Order For Interrogatories in California

    Uploaded by

    Stan Burman
    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. 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. 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. 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. Note that the author is NOT an attorney and no guarantee or warranty is provided.

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
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    The document discusses filing an opposition to a motion for protective order regarding interrogatories in a California civil case.

    An opposition to a motion for protective order is filed to argue against granting the protective order sought in the moving party's motion.

    The opposition argues that the moving party failed to show good cause for the protective order and that the interrogatories are relevant, not overbroad or vague, and comply with the discovery statutes.

    1 Any Attorney or Party

    Any Street
    2 Any Town, CA 55555

    3 714-555-5555

    4 Any Attorney or Party

    8 Superior Court of the State of California

    9 For the County of _________________

    10

    11 Any Plaintiff, ) Case No.


    )
    12 Plaintiff, ) OPPOSITION TO MOTION FOR PROTECTIVE
    vs. ) ORDER FOR SPECIAL INTERROGATORIES;
    13 ) AND FOR SANCTIONS; MEMORANDUM OF
    ) POINTS AND AUTHORITIES; DECLARATION OF
    14 Any Defendants, and DOES 1-5, inclusive, ) _________; EXHIBITS
    )
    15 Defendants. ) DATE:
    ) TIME:
    16 ) DEPT:
    )
    17 )
    )
    18 )
    )
    19

    20 To subscribe to my FREE weekly legal newsletter visit


    21

    22
    http://legaldocspro.net/newsletter.htm and enter your e-mail address.
    23
    To view over 300 sample legal documents sold by LegalDocsPro
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    25 visit: http://www.scribd.com/LegalDocsPro
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    Be sure to remove this notice and all other notices before using
    27

    28 this document.
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    OPPOSITION TO MOTION FOR PROTECTIVE ORDER-INTERROGATORIES


    1 NAME AND PARTY CAPACITY herein submits its Opposition to the motion for a
    2 protective order and for sanctions filed by NAME AND PARTY CAPACITY on the grounds that (1)
    3
    the moving party has failed to meet their burden of showing good cause for the protective order, (2)
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    the information sought by the interrogatories is clearly relevant to the issues involved in this case as it
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    relates to the claim or defense of the moving party and therefore meets the relevancy standard

    7 imposed by Code of Civil Procedure 2017.010, (3) that the interrogatories are not overbroad and

    8 oppressive or vague and ambiguous, and (4) that the interrogatories are not excessive and were
    9
    served with a valid, executed declaration for additional discovery in compliance with Code of Civil
    10
    Procedure 2030.040(a), 2030.050.
    11
    NAME AND PARTY CAPACITY further requests the sum of $____ in sanctions against the
    12

    13 moving party pursuant to Code of Civil Procedure 2030.090 on the grounds that the moving party

    14 filed their motion for a protective order without a showing of good cause.
    15
    The Opposition shall be based on this Opposition, the attached memorandum of points and
    16
    authorities, the declaration of ___________and exhibits attached thereto, on the complete files and
    17
    records of this action, and on such other oral and/or documentary evidence as may be presented at the
    18

    19 hearing on the Motion.

    20 Dated________________ _______________________________________________
    ANY ATTORNEY OR PARTY
    21

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    Be sure to modify these paragraphs to suit your individual
    23

    24 situation. Do NOT just use the wording here unless it definitely applies
    25

    26 to your particular situation. Remember that YOUR OPPOSITION


    27
    MUST BE SERVED AND FILED AT LEAST NINE (9) COURT DAYS
    28

    - 2 -

    OPPOSITION TO MOTION FOR PROTECTIVE ORDER-INTERROGATORIES


    1 BEFORE THE HEARING. Court days means Monday through
    2

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    Friday, except for Court holidays. You should serve your opposition by
    4
    personal delivery or overnight mail. See Code of Civil Procedure
    5

    6 section 1005 for more details.


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    To purchase the entire 15 page document visit:
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    https://legaldocspro.myshopify.com/products/sample-
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    11 opposition-to-motion-for-protective-order-for-interrogatories-
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    13 in-california
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    - 3 -

    OPPOSITION TO MOTION FOR PROTECTIVE ORDER-INTERROGATORIES

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