Kinsey Law Offices 
Notice Of Motion For Protective Order
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    (Name, Address Of Party or attorney)
    ____________
    ____________
    ____________
    State Bar No: ______
    (____) _____ - ________
    Attorney for _______ (Or "In Pro Per")

 

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF ________

 

[PLAINTIFF(S) NAMES]
Plaintiffs,

 

v.
 
[DEFENDANT(S) NAMES]
Defendants
 
 
________________________________
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CASE NO: _______
 
NOTICE OF MOTION FOR PROTECTIVE ORDER AND FOR IMPOSITION OF SANCTIONS
 
Date: ______
Time: ______
Place: ______
Trial Date: _____

To __________ [name of deposing party], __________ [deposing
party's attorney], attorney of record for __________ [deposing
party], and to __________ [names of other parties or attorneys
on whom copies of deposition notice or subpoena were served]:

PLEASE TAKE NOTICE that at __________ [time], on __________
[date], or as soon after as the matter can be heard, in
__________ [Department or as the case may be] of the __________
County Superior Court, __________ [court address], __________
[moving party] will move the court for a protective order
__________ [specify type of protective orders sought, for
instance: that plaintiff's deposition not be taken. In the
alternative, __________ (moving party) seeks an order preventing
__________ (deposing party) from inquiring into matters
protected by the attorney-client privilege or the work product
rule. Further, __________ (moving party) seeks an order that
all or portions of the writings and tangible things designated
for production in the deposition notice not be produced,
inspected, or copied; or that only those items be produced that
are not protected by the attorney-client privilege and the work
product rule.] This motion is made on the grounds that
__________ [specify, for example: __________ (deposing party)
seeks disclosure at __________ (deponent's) deposition of
information, including writings that reflect __________
(deponent's attorney's) impressions, conclusions, opinions, and
legal research. Such information is protected by the
attorney-client privilege and by the work product rule, and is
thus not discoverable]. __________ [If sanctions are sought,
add the following: Pursuant to section 2023(b)(1) of the Code
of Civil Procedure, __________ (moving party) will also seek
monetary sanctions of $__ against __________ (noticing party and
his or her attorney or as the case may be) for __________
(reasonable attorney fees and costs incurred in bringing this
motion or as the case may be). Such sanctions are sought on the
ground that there is not substantial justification for
__________ (noticing party's) conduct in __________ (specify
conduct for which sanctions are sought).]

The motion will be based on this notice of motion, the
attached memorandum of points and authorities, the declaration
of __________ [name of witness or attorney or as the case may
be], the record and files of this case, and any further oral or
documentary evidence introduced at the hearing of this motion.

Dated __________.

______________________________
[Signature]
Attorney for __________ [moving party]

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