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 DEPOSITION OF __________;
)
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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- 1 -
NOTICE OF MOTION AND MOTION FOR PROTECTIVE ORDER-DEPOSITION
 1 Be sure to remove this notice and all other notices before using
2

3
this document.
4 TO: _____________________________ AND THEIR ATTORNEY OF RECORD HEREIN:
5
PLEASE TAKE NOTICE that on ____________, 20___, at _______.m. or as soon thereafter
6
as the matter may be heard, in Department ________ of the above-entitled court, located at
7

8
__________________________, ___________________________will and hereby does move this

9 Court:

10 1. For a protective order that LIST HERE THE SPECIFIC ORDER THAT YOU
11
SEEK SUCH AS CERTAIN INDIVIDUALS SHALL NOT BE PRESENT AT THE
12
DEPOSITION, THE DEPOSITION BE TAKEN ON A DIFFERENT DATE, THE
13
DEPOSITION NOT BE TAKEN AT ALL, ETC., on the grounds that LIST HERE THE
14

15 SPECIFIC FACTS AND EVIDENCE THAT SUPPORT YOUR REQUEST FOR A

16 PROTECTIVE ORDER SUCH AS UNLESS A PROTECTIVE ORDER IS ISSUED THE

17
MOVING PARTY WILL SUFFER UNWARRANTED ANNOYANCE, EMBARASSMENT,
18
OPPRESSION OR UNDUE BURDEN AND EXPENSE.
19
2. For a protective order that the moving party need not produce any of the requested
20

21 documents in categories __ through ___ at the deposition on the grounds that unless a protective

22 order is issued the moving party will suffer unwarranted annoyance, embarrassment, or oppression,
23
or undue burden and expense pursuant to Code of Civil Procedure 2025.420(b); and
24
3. For an order of sanctions as against ______________________________, in the
25
amount of $____________ for their blatant failure and refusal to meet and confer in a reasonable
26

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

28

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NOTICE OF MOTION AND MOTION FOR PROTECTIVE ORDER-DEPOSITION
 1 This motion is brought pursuant to Code of Civil Procedure 2025.420 et seq., on the
2 grounds that unless a protective order is issued the moving party will suffer unwarranted annoyance,
3
embarrassment, or oppression, or undue burden and expense pursuant to Code of Civil Procedure
4
2025.420(b) and on the further grounds that the requested documents do not relate in any way to the
5

6
claim or defense of either the requesting party nor any other party to this action and thus the requests

7 fail to meet the relevancy standard imposed by Code of Civil Procedure 2017.010.

8 The moving party further requests the sum of $___________ in sanctions against
9
_____________________ pursuant to Code of Civil Procedure 2025.420(h).
10
This Motion is made upon the grounds that ____________ the moving party has made
11
reasonable good faith efforts to reach an informal resolution of this matter without the need for
12

13 judicial intervention but ___ has rebuffed all efforts.

14 This motion is based upon this notice, the attached memorandum of points and authorities,
15
declaration of _____________, and exhibits, and upon such further oral and documentary evidence
16
as may be presented to the Court by at the time of the hearing.
17

18

19 Dated________________ _______________________________________________
ANY ATTORNEY OR PARTY
20

21
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24

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NOTICE OF MOTION AND MOTION FOR PROTECTIVE ORDER-DEPOSITION