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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 _________________

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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 )
)
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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.
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TO: _____________________________ AND THEIR ATTORNEY OF RECORD HEREIN:
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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
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Court pursuant to Code of Civil Procedure 2033.080:
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1. For a protective order that the moving party need not respond to requests for
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admission __ through __ of Set ___, on the grounds that that number of requests for admission is
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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
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whenever a party propounds more than 35 specially prepared requests for admission not related to the
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genuineness of documents;
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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
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constitute an unwarranted annoyance on the moving party.
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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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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
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grounds that ____________ propounded more than 35 specially prepared requests for admission not
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relating to the genuineness of documents without including the supporting declaration required by
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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.
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The moving party further requests pursuant to Code of Civil Procedure 2033.080(d) the sum
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of $___________ in sanctions against _____________________.
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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.


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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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be presented to the Court by _________________ at the time of the hearing.
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13 Be sure to modify these paragraphs to suit your individual


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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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18 not represented by an attorney.


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Dated________________ _______________________________________________
21 ANY ATTORNEY OR PARTY
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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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NOTICE OF MOTION AND MOTION FOR PROTECTIVE ORDER-REQUESTS FOR ADMISSION