This document is a notice of motion for a protective order regarding a set of interrogatories in a legal case. It gives notice that a party will move for a protective order on the grounds that the interrogatories exceed the limit of 35 without required declaration and some interrogatories are unduly burdensome. It also moves for monetary sanctions for failure to meet and confer in good faith to resolve the issues. The motion is made under relevant code sections and requests the protective order and sanctions be granted based on the notice, attached memorandum and declaration, and evidence presented at hearing.

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Any Attorney or Party
Any Street
Any Town, CA 55555
714-555-5555
Any Attorney or Party
Superior Court of the State of California
For the County _________________
Any Plaintiff,
Plaintiff,
vs.
Any Defendant,
Defendant.
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Case No.
NOTICE OF MOTION FOR PROTECTIVE ORDER
REGARDING SPECIAL INTERROGATORIES;
AND FOR MONETARY SANCTIONS IN THE
AMOUNT OF $_________, MEMORANDUM OF
POINTS AND AUTHORITIES, DECLARATION
OF __________, EXHIBITS
DATE: TIME:
DEPT:
1TO: _____________________________ AND THEIR ATTORNEY OF
RECORD HEREIN:
PLEASE TAKE NOTICE that on ____________, 20___, at _______.m. or as soon thereafter
as the matter may be heard, in Department ________ of the above-entitled court, located at
__________________________, ___________________________will and hereby do move this
Court:
1. For a protective order that the moving party need not answer interrogatories 36
through __ of Set One, on the grounds that no declaration for additional discovery was included as
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NOTICE OF MOTION AND MOTION FOR PROTECTIVE ORDER-INTERROGATORIES

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required by Code of Civil Procedure Section 2030.050 which requires that a specifically worded
declaration be included whenever a party propounds more than 35 specially prepared interrogatories;
2. For a protective order that the moving party need not answer interrogatories LIST
NUMBERS HERE of Set One, on the grounds that unless a protective order is issued the moving
party will suffer unwarranted annoyance, embarrassment, or oppression, or undue burden and
expense pursuant to Code of Civil Procedure section 2030.090(b) and Code of Civil Procedure
section 2030.090(b)(1); and
3. For an order of sanctions as against ______________________________, in the
amount of $____________ for their blatant failure and refusal to meet and confer in a reasonable
good faith effort to reach an informal resolution of this matter.
This motion is brought pursuant to Code of Civil Procedure Section 2016.010 et seq., on the
grounds that ____________ propounded more than 35 specially prepared interrogatories without
including the supporting declaration required by law, and has propounded ___ specially prepared
interrogatories that clearly do not relate to the claim or defense of the party seeking discovery or of
any other party to the action as required by Code of Civil Procedure section 2017.010, and on the
further grounds that the interrogatories are unduly burdensome and oppressive.
The moving party further requests pursuant to Code of Civil Procedure section 230.090(d),
the sum of $___________ in sanctions against _____________________.
This Motion is made upon the grounds that ____________ the moving party has made
reasonable good faith efforts to reach an informal resolution of this matter without the need for
judicial intervention but ___ has rebuffed all efforts.
This motion is based upon this notice, the attached memorandum of points and authorities,
declaration of _____________, and exhibits, and upon such oral and documentary evidence as may
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NOTICE OF MOTION AND MOTION FOR PROTECTIVE ORDER-INTERROGATORIES

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be presented to the Court by _________________ at the time of the hearing.
Be sure to modify these paragraphs to suit your individual
situation. Do NOT just use the wording here unless it definitely applies
to your particular situation. Do NOT ask for attorney’s fees if you are
not represented by an attorney.
1Dated________________ _______________________________________________
ANY ATTORNEY OR PARTY
To view the sample document on which this preview is based visit:
http://www.scribd.com/doc/215689466/Sample-Motion-for-Protective-
Order-Regarding-Interrogatories-for-California
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NOTICE OF MOTION AND MOTION FOR PROTECTIVE ORDER-INTERROGATORIES