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Any Street
2 Any Town, CA 55555
3 714-555-5555
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25 Court:
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1. For a protective order that the moving party need not answer interrogatories 36
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through __ of Set One, on the grounds that no declaration for additional discovery was included as
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NOTICE OF MOTION AND MOTION FOR PROTECTIVE ORDER-INTERROGATORIES
1 required by Code of Civil Procedure 2030.050 which requires that a specifically worded declaration
2 be included whenever a party propounds more than 35 specially prepared interrogatories;
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2. For a protective order that the moving party need not answer interrogatories LIST
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NUMBERS HERE of Set One, on the grounds that unless a protective order is issued the moving
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party will suffer unwarranted annoyance, embarrassment, or oppression, or undue burden and
7 expense pursuant to Code of Civil Procedure 2030.090(b) and0 Code of Civil Procedure
8 2030.090(b)(1); and
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3. For an order of sanctions as against ______________________________, in the
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amount of $____________ for their blatant failure and refusal to meet and confer in a reasonable
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good faith effort to reach an informal resolution of this matter.
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13 This motion is brought pursuant to Code of Civil Procedure 2016.010 et seq., on the
14 grounds that ____________ propounded more than 35 specially prepared interrogatories without
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including the supporting declaration required by law, and has propounded ___ specially prepared
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interrogatories that clearly do not relate to the claim or defense of the party seeking discovery or of
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any other party to the action as required by Code of Civil Procedure 2017.010, and on the further
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20 The moving party further requests pursuant to Code of Civil Procedure 2030.090(d), the
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sum of $___________ in sanctions against _____________________.
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This Motion is made upon the grounds that ____________ the moving party has made
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reasonable good faith efforts to reach an informal resolution of this matter without the need for
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26 This motion is based upon this notice, the attached memorandum of points and authorities,
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declaration of _____________, and exhibits, and upon such oral and documentary evidence as may
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NOTICE OF MOTION AND MOTION FOR PROTECTIVE ORDER-INTERROGATORIES
1 be presented to the Court by _________________ at the time of the hearing.
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Be sure to modify these paragraphs to suit your individual
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4 situation. Do NOT just use the wording here unless it definitely applies
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to your particular situation. Do NOT ask for attorneys fees if you are
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Dated________________ _______________________________________________
ANY ATTORNEY OR PARTY
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https://legaldocspro.myshopify.com/products/sample-motion-for-
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protective-order-regarding-interrogatories-for-california
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NOTICE OF MOTION AND MOTION FOR PROTECTIVE ORDER-INTERROGATORIES