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 _________________

10

11 Any Plaintiff, ) Case No.

)
12 NOTICE OF MOTION FOR PROTECTIVE ORDER
Plaintiff, )
REGARDING REQUESTS FOR ADMISSION;
)
13 AND FOR MONETARY SANCTIONS IN THE
vs. )
AMOUNT OF $_________, MEMORANDUM OF
)
14 POINTS AND AUTHORITIES, DECLARATION OF
Any Defendant, )
__________, EXHIBITS
)
15 Defendant. ) DATE: TIME:
) DEPT:
16 )
)
17 )
)
18

19
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address.
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Be sure to remove this notice and all other notices before
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NOTICE OF MOTION AND MOTION FOR PROTECTIVE ORDER-REQUESTS FOR ADMISSION
 1 using this document.
2
TO: _____________________________ AND THEIR ATTORNEY OF RECORD HEREIN:
3

4
PLEASE TAKE NOTICE that on ____________, 20___, at _______.m. or as soon thereafter

5 as the matter may be heard, in Department ________ of the above-entitled court, located at
6 __________________________, ___________________________will and hereby does move this
7
Court pursuant to Code of Civil Procedure 2033.080:
8
1. For a protective order that the moving party need not respond to requests for
9
admission __ through __ of Set ___, on the grounds that that number of requests for admission is
10

11 unwarranted, and that no declaration for additional discovery was included as required by Code of

12 Civil Procedure 2033.050 which requires that a specifically worded declaration be included
13
whenever a party propounds more than 35 specially prepared requests for admission not related to the
14
genuineness of documents;
15
2. For a protective order that the moving party need not respond to requests for
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17 admission __ through ___ of Set __ on the grounds that said requests for admission are not related to

18 any conceivable triable issues in this case, and on the further grounds that said requests for admission
19
constitute an unwarranted annoyance on the moving party.
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3. For an order of sanctions as against ______________________________, in the
21
amount of $____________ for their blatant failure and refusal to meet and confer in a reasonable
22

23 good faith effort to reach an informal resolution of this matter.

24 This motion is brought pursuant to Code of Civil Procedure 2033.010 et seq., on the
25
grounds that ____________ propounded more than 35 specially prepared requests for admission not
26
relating to the genuineness of documents without including the supporting declaration required by
27
law, has propounded requests for admission are not related to any conceivable triable issues in this
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NOTICE OF MOTION AND MOTION FOR PROTECTIVE ORDER-REQUESTS FOR ADMISSION
 1 case, and on the further grounds that said requests for admission constitute an unwarranted annoyance
2 on the moving party.
3
The moving party further requests pursuant to Code of Civil Procedure 2033.080(d) the sum
4
of $___________ in sanctions against _____________________.
5

6
This Motion is made upon the grounds that ____________ the moving party has made

7 reasonable good faith efforts to reach an informal resolution of this matter without the need for

8 judicial intervention but ___ has rebuffed all efforts.

9
This motion is based upon this notice, the attached memorandum of points and authorities,
10
declaration of _____________, and exhibits, and upon such oral and documentary evidence as may
11
be presented to the Court by _________________ at the time of the hearing.
12

13 Be sure to modify these paragraphs to suit your individual

14

15
situation. Do NOT just use the wording here unless it definitely applies
16
to your particular situation. Do NOT ask for attorneys fees if you are
17

18 not represented by an attorney.

19

20
Dated________________ _______________________________________________
21 ANY ATTORNEY OR PARTY
22
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24
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25

26 for-protective-order-regarding-requests-for-admission-for-
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NOTICE OF MOTION AND MOTION FOR PROTECTIVE ORDER-REQUESTS FOR ADMISSION
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