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 PRODUCTION
)
13 OF DOCUMENTS; AND FOR MONETARY
vs. )
SANCTIONS IN THE AMOUNT OF $_________,
)
14 MEMORANDUM OF POINTS AND
Any Defendant, )
AUTHORITIES, DECLARATION OF __________,
)
EXHIBITS
15 Defendant. )
) DATE: TIME:
16 )
DEPT:
)
17 )
)
18

19
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- 1 -
NOTICE OF MOTION AND MOTION FOR PROTECTIVE ORDER-REQUEST FOR DOCUMENTS
 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 the moving party need not respond to or produce any of the
11
requested documents in categories LIST NUMBERS HERE of requests for production of
12
documents, Set One, on the grounds that none of the requested documents relate to the claim or
13
defense of either the requesting party nor any other party to this action and thus the requests for
14

15 production of documents fail to meet the relevancy standard imposed by California law.

16 2. For a protective order that the moving party need not respond to or produce any of the
17
requested documents in categories the grounds that unless a protective order is issued the moving
18
party will suffer unwarranted annoyance, embarrassment, or oppression, or undue burden and
19
expense pursuant to Code of Civil Procedure 2031.060(b) and Code of Civil Procedure
20

21 2031.060(b)(1); and

22 3. For an order of sanctions as against ______________________________, in the

23
amount of $____________ for their blatant failure and refusal to meet and confer in a reasonable
24
good faith effort to reach an informal resolution of this matter.
25
This motion is brought pursuant to Code of Civil Procedure 2016.010 et seq., on the
26

27 grounds that ____________ propounded requests for the production of documents that do not relate

28 in any way to the claim or defense of either the requesting party nor any other party to this action and

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NOTICE OF MOTION AND MOTION FOR PROTECTIVE ORDER-REQUEST FOR DOCUMENTS
 1 thus the requests fail to meet the relevancy standard imposed by Code of Civil Procedure 2017.010,
2 and on the further grounds that unless a protective order is issued the moving party will suffer
3
unwarranted annoyance, embarrassment, or oppression, or undue burden and expense,
4
The moving party further requests the sum of $___________ in sanctions against
5

6
_____________________ pursuant to Code of Civil Procedure 2031.060(h).

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8

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10
protective-order-regarding-production-of-documents-for-california
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NOTICE OF MOTION AND MOTION FOR PROTECTIVE ORDER-REQUEST FOR DOCUMENTS