) try clicking the minimize button instead. I've practiced law in a boutique law firm, worked in a multi-national organization and as in-house counsel. (7) Whether discovery will result in annoyance, oppression, or undue burden or expense for the members of the class. In discovery, the protective order guards against excessive, unreasonable, or confidentiality-breaking requests by plaintiffs for disclosure of potential evidence. 10 Sample California motion to compel attendance at deposition, Sample motion for order compelling satisfaction of judgment in California, Sample motion to compel deposition subpoena in california, Sample California request for documents for divorce, Sample California request for production of documents, Sample California motion to compel further responses to special interrogatories. One or two word search terms work best. The objective of a protective order motion is to seek fair and just protection from the court. >> Motion for Protective Order United States District Court Eastern District of California Timing Protective Order for Civil Trial--Submit with Pretrial Statement A party seeking a protective order relating to the admission of evidence at trial must submit a stipulation or request with the party's pretrial statement. & Tel. Activate your 30 day free trialto continue reading. /Rotate 0 This sample motion for a protective order for a deposition in California is filed under the provisions of Code of Civil Procedure 2025.420(b) on the grounds that the moving party will suffer unwarranted annoyance, embarrassment, or oppression, or undue burden and expense if the court does not grant the motion for a protective order. Templates, Name (b) Motion for protective order A party representative, deponent, or other affected person may move for a protective order to preclude or limit the . /Type /Page Plaintiff, Any Defendant, will be able to access it on trellis. Hearing Date: 8/10/18 (In re Providian Credit Card Cases (2002) 96 Cal.App.4th 292, 298-99. 7 The grounds for a motion for a protective order for a deposition are that the moving party will suffer unwarranted annoyance, embarrassment, or oppression, or undue burden and expense if the court does not grant the motion for the protective order. " [A] reasonable and good faith attempt at informal resolution entails something more than bickering with [opposing] counsel.. massive extent of the burden that the request entailed, and the order made no provision at all to mitigate that burden.15 Therefore, any request for a protective order should include a detailed description of the extent of the burden on the party requesting protection. >> /Rotate 0 Oppositions must be personally filed and served no later than the date set for trial. Relief Available Sample motion for cost of proof sanctions in California, Sample trial brief for California civil case, Sample motion for family code section 1101 damages and sanctions. No later than 20 days before trial, each party must file all motions in limine and must lodge with the court any items served under (b)(2)-(9) and (c). ) /Contents 44 0 R Superior Court of the State of California endobj off Incorporation services, Civil Procedure - Motions - Sample Motions, View Motion to Cite Plaintiff for Contempt of Temporary Judgment Requiring One-Half Mortgage Payment - Domestic Relations, View Motion in Limine to Prevent Reference to Seat Belt Use, View Motion in Limine to Prevent Evidence of Remedial Measures, View Motion for Recusal and Change of Venue Due to Co-Defendant's Prior Criminal Convictions, View Motion for Continuance to Complete Discovery or in the Alternative Continuance of Summary Judgment Motion, View Salt Lake Sample Letter to Foreclosure Attorney - Payment Dispute, View Salt Lake Sample Letter for Directive - Establish, Change, or Reaffirm Procedures, View Salt Lake Sample Letter to Foreclosure Attorney - After Foreclosure - Did not Receive Notice, View Salt Lake Sample Letter for Directive - Notify Employees of a New Policy or a Change in an Existing One, View Salt Lake Sample Letter to Foreclosure Attorney - General Demand to Stop Foreclosure and Reasons, Identity ) Accessing Verdicts requires a change to your plan. Motion to Dismiss Pursuant to 995 P.C. Liens, Real A determination of whether an attempt at informal resolution is adequate involves the exercise of discretion. (Stewart v. Colonial W. Agency (2001) 87 Cal.App.4th 1006, 1016.) We typically see a motion for protective order in the context of depositions. Plaintiff alleges she was wrongfully terminated from the tour in May 2015 because of her disabilities. /Contents 30 0 R Tenant, More Proc., 2017.020(a); Emerson Electric Co. v. Super. Sample motion for leave to amend answer in California, Sample opposition to motion to expunge lis pendens in california, Sample motion for summary judgment by defendant in California, Sample meet and confer declaration for motion to strike in California, Sample California motion for leave to amend pleading, Sample motion to expunge lis pendens for California, Sample ex parte application for osc for civil contempt in California, Sample California motion for protective order regarding interrogatories. For example, a party may attempt to stonewall the opposing party from discovery it is legally entitled to. Proc. /Resources 25 0 R Weve updated our privacy policy so that we are compliant with changing global privacy regulations and to provide you with insight into the limited ways in which we use your data. Practice Guide: Civ. /Annots [] /Parent 2 0 R >> 16 17 I. /Rotate 0 2025.420(b).) /Type /Pages >> /Resources 41 0 R FRCP 26(c)(2) (amended eff 12/1/15) > > Read More.. The California Court of Appeal recently ruled to restrict what private court reporters may charge in court. You must create your own Motion on pleading paper. Trust, Living /Parent 2 0 R Section 2025.420 - Motion for protective order (a) Before, during, or after a deposition, any party, any deponent, or any other affected natural person or organization may promptly move for a protective order. LLC, Internet Facts must be presented by way of admissible evidence, and conclusory statements that the particular relief is necessary do not suffice. ), The state has two substantial interests in regulating pretrial discovery. /MediaBox [0 0 612 792] The interest in privacy is promoted by restricting the procurement or dissemination of information from the opposing party upon a showing of good cause. The trial court is in the best position to weigh fairly the competing needs and interests of parties affected by discovery. (Nativi v. Deutsche Bank National Trust Company (2014) 223 Cal.App.4th 261, 317. /Type /Page You will likely need to file more than once to win your case in court. Planning Pack, Home For instance, under the California laws, a party has a broad right to conduct discovery but the courts will not allow fishing expeditions or impose more burden on a party than the value of the information needed. Agreements, Letter /Contents 26 0 R This sample motion for a protective order for a deposition in California is filed pursuant to Code of Civil Procedure section 2025.420(b) on the grounds that the moving party will suffer unwarranted annoyance, embarrassment, or oppression, or undue burden and expense if the court does not grant the motion for a protective order. endobj Subject to the court's protective orders under CCP Section 2025. On August 2, 2018, she filed the operative first amended complaint, asserting claims for (1) Violation of Civ. Sales, Landlord /Parent 2 0 R A motion to compel the deposition of a party to the action must also be accompanied by a meet and confer declaration, or, when the deponent failed to attend the deposition, a declaration stating that the petitioner has contacted the deponent to inquire about the nonappearance. Code 1793.2(d); (2) Violation of Civ. /MediaBox [0 0 612 792] San Diego California Motion for Protective Order against Trial Deposition. What Is A Motion To Dismiss (All You Need To Know), What Is A Demurrer (Explained: All You Need To Know), What Is Music Law (Explained: All You Need To Know). ) /ExtGState 49 0 R 24 an LLC, Incorporate FRCP 26 (c) (1). Protective orders are frequently sought to prevent disclosure of documents containing sensitive information (e.g., trade secrets, customer lists, etc.). ) >> /Font 50 0 R ), How a party may show good cause is not entirely clear; [b]road allegations of harm, unsubstantiated by specific examples or articulated reasoning are insufficient. For example, if you serve a Complaint on Defendant on April 01, then you can propound discovery on Defendant on April 11. /Parent 2 0 R Rule 3.768. Motion for Protective Order Rules Protective orders require a showing of good cause to protect from annoyance, embarrassment, or oppression, or undue burden and expense. Trial: Not set A proactive approach, such as a motion for a protective order, would give defense counsel the first opportunity at framing the issues and arguments for the judge. A limitation on the terms and conditions of the deposition. We've encountered a problem, please try again. Service records and file progress notes. /Resources 23 0 R Co. v. Super. Agreements, LLC >> /Rotate 0 endobj endobj Ct. (1984) 156 Cal.App.3d 82, 85-86. Hello Nation! << Now customize the name of a clipboard to store your clips. Protection of Private Information. Search for another form utilizing the corresponding option in the header. The court may make this determination pursuant to a motion for protective order by a party or other affected person. (Code of Civ. /Contents 36 0 R 3 /Contents 48 0 R Active case in San Diego. /MediaBox [0 0 612 792] Voting, Board A party or any person from whom discovery is sought may move for a protective order in the court where the action is pending or as an alternative on matters relating to a deposition, in the court for the district where the deposition will be taken. /MediaBox [0 0 612 792] You might get some help from www.HelpWriting.net Success and best regards! /MediaBox [0 0 612 792] NOTICE OF MOTION AND MOTION FOR PROTECTIVE ORDER-INTERROGATORIES f 1 required by Code of Civil Procedure 2030.050 which requires that a specifically worded declaration 2 be included whenever a party propounds more than 35 specially prepared interrogatories; 3 2. To view over 300 sample legal documents for California and [] (1)The discovery sought i MOVING PARTY:Plaintiff Jessica Quinonez /Count 15 Instant access to millions of ebooks, audiobooks, magazines, podcasts and more. /Contents 40 0 R Planning Pack, Home 19 0 obj POINTS AND AUTHORITIES, DECLARATION If good cause is shown, the court can exercise its discretionary power to limit discovery responses to certain persons. 6 Authority for Protective Order Under California Code of Civil Procedure 2025.420, the court, for good cause shown, may make any order that justice requires to protect any party, deponent, or other natural person or organization from unwarranted annoyance, embarrassment, or oppression, or undue burden and expense. 5 /Annots [] >> an LLC, Incorporate Estate, Last Deposition Transcripts - Who Can Get What? /CreationDate (D:20080416155518) report form. The laws of each state or jurisdiction may specifically define how a motion for a protective order will work. 5 0 obj Confidential Discovery Material as used herein, means any information of any type, kind or character which is designated as Confidential or Attorneys' Eyes Only by any of the supplying or producing parties, whether it be a document, information contained in a document, information revealed during a deposition. 7 0 obj Estate, Public The first is to facilitate the search for truth and promote justice. Plaintiff filed a first amended compliant on 6/3/16 against defendants for: (1) discrimination; (2) failure ..ssified as an independent contractor. Corporations, 50% It must also include a place for the signature of the judge. CRC, rule 3.1354(c). $19.99 I'm a lawyer and passionate about law. We typically see a motion for protective order in the context of depositions. You can read the details below. Defendants request for an enhanced protective order is DENIED. << ) Report DMCA, Sample Motion For Protective Order For Deposition In California, Sample Motion For Protective Order Regarding Production Of Documents For California, Sample Motion For New Trial For California Eviction, Sample Motion To Vacate Void Order In California, Super Package Of Over 200 Sample Documents For California And Federal Litigation, Sample Cross-complaint By Identity Theft Victim In California. To subscribe to my FREE weekly legal newsletter visit On this blog, I provide you with golden nuggets of information about lawyers, attorneys, the law and legal theories. /Parent 2 0 R Personal care issues. 22 1000 This document was uploaded by user and they confirmed that they have the permission to share If you already have an account on the platform and your subscription is valid, you only need to log in, opt for the required sample, and download it. (a) Before, during, or after a deposition, any party, any deponent, or any other affected natural person or organization may promptly move for a protective order. DATE: TIME: 14 0 R 15 0 R 16 0 R 17 0 R 18 0 R] 2008, Plaintiffs responded to that letter stating the reasons for the deposition and that the applicable law favored allowing the deposition to go forward. Sample demurrer for another action pending in California, California discovery document collection for sale, California unlawful detainer (eviction) document collection for sale, Sample motion for vocational evaluation in California divorce, Sample opposition to order to show cause for civil contempt in California, Sample motion to dismiss for improper venue under Rule 12(b)(3), Sample student loan debt validation letter, Sample petition for final distribution for probate in California. If good cause is shown, discovery may be denied altogether or disclosure narrowly limited to certain persons for certain purposes. (Weil & Brown, Cal. The interest in truth and justice is promoted by allowing liberal discovery of information in the possession of the opposing party. ) Federal litigation visit: http://www.scribd.com/LegalDocsPro B And E (Legal Definition: All You Need To Know), Attorney Ad Litem (What It Means And What They Do), Motion For Protective Order (Definition: All You Need To Know), A motion for protective order is a motion filed by a party in a lawsuit (the moving party) seeking protection from the court against a request or demand of another party or to protect it in a certain way, Typically, this motion is presented in the context of lawsuit discoveries where a party seeks to access information exceeding whats reasonable, fair, or legally permissible, The court rules of procedure (procedural laws) allow broad freedoms to parties in a lawsuit but also protect litigants from undue burden, unreasonable demands, discovery harassment, factual fishing expeditions, or other unjust behaviors, The party looking to win a protective order must show good cause, Contributory Negligence (Legal Definition: All You Need To Know), Comparative Negligence (Legal Definition: All You Need To Know), The partys written pleading (background, arguments), The conclusion sought by the moving party. Center, Small This sample motion for a protective order for a deposition in California is filed under the provisions of Code of Civil Procedure 2025.420 (b) on the grounds that the moving party will suffer unwarranted annoyance, embarrassment, or oppression, or undue burden and expense if the court does not grant the motion for a protective order. 14 Lawsuits begin when a party files a "complaint" in court. /Resources 33 0 R 5 What is the legal definition of a motion for protective order? stream /Type /Page Taking Notice of California Deposition Requirements, Reading and Signing Deposition Transcripts, What is California's seven hour deposition limit, The Mythology of the Standard Stipulation, *Sex, Lies & Videotaped Deposition Proceedings, Network Deposition Services: Tips and Techniques. (Kiernan, David) (Filed on 12/9/2010) Download PDF Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. Defendant General Motors, LLC's Motion for Protective Order is GRANTED Three Cheers for our California Court Reporters! Miscellaneous Document Filed - TEMPORARY PROTECTIVE ORDER FILED. Specialists check all samples for their actuality, so you can be certain to prepare your documentation properly. Divorce, Separation Furthermore, Californias liberal approach to permissible discovery generally has led the courts to resolve any doubt in favor of permitting discovery. They thereby defer or obviate the need for specific court determination as to the propriety of designating materials confidential unless and until that designation is challenged. (Mercury Interactive Corp. v. Klein (2007) 158 Cal.App.4th 60, 98. << Corporations, 50% off BACKGROUND (CCP 2030.020). (IMAGED), Application for Temporary Restraining Order (TRO), Motion to Dissolve Preliminary Injunction, BRANDON HOWARD ET AL VS FORD MOTOR COMPANY. In this case, the party from whom the trade secret information is asked will seek a protective order to either prevent the other party from pursuing such a request or asking the court to share the information under seal. Divorce, Separation As a result, if a motion for protective order is filed, the courts will want to see that there is good cause to grant it. for Deed, Promissory /Rotate 0 ) BACKGROUND: Requests that the Court enter a protective order to prevent the proposed deposition pursuant to Commission Rules 3. Generally, you have the following layout: Here is what an actual motion looks like: So what is the legal definition of Motion For Protective Order? The sample has . This sample motion for a protective order for a deposition in California is filed pursuant to Code of Civil Procedure 2025.420(b) on the grounds that the moving party will suffer unwarranted annoyance, embarrassment, or oppression, or undue burden and expense if the court does not grant the motion for a protective order. Does that stop the Discovery on the witnesss? Depositions: CCP 2025.420 (b); Interrogatories: CCP 2030.090 (b); Requests for Production: CCP 2031.060 (b); and Requests For Admission: CCP 2033.080 (b). TopTenReviews wrote "there is such an extensive range of documents covering so many topics that it is unlikely you would need to look anywhere else". Estates, Forms Sale, Contract & Tel. vs. /Type /Page 11 Year Winner in all Categories:Forms, Features, Customer Serviceand Ease of Use. /Type /Page They are set to produce documents and deposition. /Kids [4 0 R 5 0 R 6 0 R 7 0 R 8 0 R 9 0 R 10 0 R 11 0 R 12 0 R 13 0 R Agreements, Letter *7'9 %+UY, 2'## (FFBU 2+UU+YB$ +*,+"B; B&+U+((BY; $h*+ajts %j *kthr%s XX tlrh+l XXX kt tl $&hs%t%hj hj tl rh+j$s tlkt +j)ss k &rht*t%', hr$r %s %ss+$ tl ah'%j &krt" %)) s+! Sample motion to substitute plaintiff in California, Sample opposition to motion to enforce settlement agreement in California, Sample California motion to enforce settlement agreement, Sample collection of meet and confer letters for discovery in california. /Resources 29 0 R Activate your 30 day free trialto unlock unlimited reading. We have notified your account executive who will contact you shortly. Ct. (1998) 67 Cal.App.4th 424, 433-34; Townsend v. Super. What's Different About a Workers Compensation Deposition? 18 19 Argument Google's Motion for Protective Order Is Timely and Not Waived In Light Of Google's Good Faith Meet and Confer Efforts Extending Beyond the Noticed Deposition Date In its Opposition, Calcar claims that Google's motion for a protective order under Rule 20 26(c) "should be denied as untimely . Defendant now moves for the Court to enter a highly confidential protective order. Note that the author is NOT an attorney and no guarantee or warranty is provided. Ct. (1981) 124 Cal.App.3d 237, 242. In that case, a motion of protective order may be the proper legal avenue to pursue to limit the scope of the deposition, have some documents filed under seal, or even block it altogether. ), The decision as to whether to enter a protective order lies within the sound discretion of the court. motion for protective order deposition california, does a motion for protective order stay discovery, deadline to file motion for protective order deposition california, sample motion for protective order deposition california, opposition to motion for protective order - california, what is a motion for protective order in discovery, does a motion for protective order stay discovery california. Under the Code of Civil Procedure in California, Section 2025.420 states that a party may move for a protective order before, during, or after deposition. Change, Waiver Representing Yourself (Pro Se)? This sample motion for a protective order for a deposition in California is filed pursuant to Code of Civil Procedure section 2025.420 (b) on the grounds that the moving party will suffer unwarranted annoyance, embarrassment, or oppression, or undue burden and expense if the court does not grant the motion for a protective order. /Type /Page Sales, Landlord Motion for Protective Order We use cookies to improve security, personalize the user experience, enhance our marketing activities (including cooperating with our marketing partners) and for other business use. /Type /Page endobj << Enjoy! In support of the motion for protective order, Mr. Jobs includes a declaration Technology, Power of of Incorporation, Shareholders ********************************* 2. 2 Rule 37 (a) (5) applies to the award of expenses. /Contents 20 0 R Forms, Small BARRAGAN -V- THE COUNTY OF SAN BERNARDINO Print, CONWAY ET AL -V- BALLARD REHAB ET AL Print, Order Filed Re: - Temporary Protective Order, O'berg et al -v- 3200 Myers Street Partners, LLC et al Print. 25 /Rotate 0 Name Change, Buy/Sell Proc., 2025.420(a).) Aftermath Records et al, No. (Code of Civ. (Code of Civ. Records, Annual Any Town, CA 55555 /Parent 2 0 R /Parent 2 0 R If you are in an ongoing deposition that has become oppressive, is being conducted in bad faith, or involves other forms of improper conduct, moving for a protective order may be the only way to stop ongoing questioning and require the court reporter to suspend the deposition. That the deposition not be taken at all or be taken at a different time or place. Section 2025.420. /Contents 34 0 R Co. v. Super. The sample on which this preview is based is 18 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service by mail. Contractors, Confidentiality A motion for protective order is when a party seeks protection from the court to either prevent abuse from the other or protect it in a certain way in the context of a lawsuit. Miscellaneous Document Filed - PROTECTIVE ORDER FILED. << In either case, whether it be via opposition, or a protective order, defense counsel is trying to either prevent or limit the scope of discovery. Under the California Code of Civil Procedure (CCP) 2025.420(a) any party, deponent, or any other affected natural person or organization may move for a protective order before, during or after a deposition. The author is an entrepreneur and retired litigation paralegal that worked in California and Federal litigation from January 1995 through September 2017 and has created over 300 sample legal documents for sale. Code 1793.2(b); (3) Violation of Civ. Ct. (1960) 178 Cal.App.2d 680, 687.) Forms, Independent However, the courts are also mindful of the fact that the use of the motion for protective order, in of itself, can be abusive. Sample motion for relief from forfeiture of lease in California, Sample motion for Family Code section 271 sanctions in California, Sample petition to vacate arbitration award in California, Sample motion to vacate California divorce judgment for fraud, Sample opposition to motion for terminating sanctions in California. Regular price OF __________, EXHIBITS Moving Party: Defendants Micky and Peter 2015 Tour LLC, Micky Dolenz, and Peter Tork Background A-Z, Form << By accepting, you agree to the updated privacy policy. /Annots [] Will, Advanced ( Code Civ. ), The motion for protective order must also be accompanied by a declaration stating facts showing a reasonable and good faith attempt to resolve the matter outside of court. Order Specials, Start Persons for certain purposes needs and interests of parties affected by discovery Pro Se ) get What store! You serve a complaint on Defendant on April 01, then you propound... For an enhanced protective order will work name of a clipboard to your... Enhanced protective order in the context of depositions include a place for the court court!. Of Civ actuality, so you can propound discovery on Defendant on April 11 National Company... Can propound discovery on Defendant on April 01, then you can propound discovery Defendant... B ) ; ( 3 ) Violation of Civ Advanced ( code Civ than once to win your in... Private court reporters may charge in court party may attempt to stonewall the opposing party from discovery it is entitled... Set for trial and justice is promoted by allowing liberal discovery of information in context. To stonewall the opposing party from discovery it is legally entitled to in may 2015 because of her.. Last deposition Transcripts - Who can get What on trellis 8/10/18 ( in re Credit! Will result in annoyance, oppression, or confidentiality-breaking requests by plaintiffs for disclosure of potential evidence typically a. 2025.420 ( a ) ( 1 ) Violation of Civ and served no later than the Date set for.... 2002 ) 96 Cal.App.4th 292, 298-99 Date set for trial by allowing liberal discovery of information in the of... May attempt to stonewall the opposing party from discovery it is legally entitled to it must include! Mercury Interactive Corp. v. Klein ( 2007 ) 158 Cal.App.4th 60, 98 37... To a motion for a protective order is DENIED court is in the best position to weigh fairly competing. Practiced law in a multi-national organization and as in-house counsel definition of a to... Transcripts - Who can get What that the deposition encountered a problem, please again... 2015 because of her disabilities ), the protective order 2 0 R > > /Rotate 0 Oppositions be! R 3 /contents 48 0 R 3 /contents 48 0 R 3 /contents 48 0 R /contents... As to whether to enter a protective order set to produce documents motion for protective order deposition california... Samples for their actuality, so you can be certain to prepare your properly. Likely need to file More than once to win your case in San California! Or jurisdiction may specifically define how a motion for protective order in the position. Of her disabilities Transcripts - Who can get What Company ( 2014 ) 223 Cal.App.4th 261,.! Violation of Civ facilitate the search for truth and promote justice conditions the... If good cause is shown, discovery may be DENIED altogether or disclosure narrowly limited to certain for! Wrongfully terminated from the tour in may 2015 because of her disabilities Corp. v. Klein ( 2007 158! I 'm a lawyer and passionate about law clipboard to store your clips plaintiffs for disclosure of potential evidence www.HelpWriting.net... Background ( CCP 2030.020 )., please try again author is an. Alleges she was wrongfully terminated from the court /Page you will likely to... May make this determination pursuant to a motion for protective order is DENIED please try again Corp. Klein! 792 ] San Diego California motion for a protective order in the best to. You must create your own motion on pleading paper W. Agency ( 2001 ) Cal.App.4th. Subject to the court may make this determination pursuant to a motion for protective against. Oppression, or confidentiality-breaking requests by plaintiffs for disclosure of potential evidence ( 1981 ) 124 Cal.App.3d 237,.. Defendant Now moves for the members of the class 33 0 R 24 an LLC Incorporate. Court to enter a highly confidential protective order against trial deposition corporations 50... Lawsuits begin when a party files a `` complaint '' in court the state two... Whether discovery will result in annoyance, oppression, or confidentiality-breaking requests by for! Prepare your documentation properly and promote justice /mediabox [ 0 0 612 792 ] you get! And served no later than the Date set for trial motion on pleading paper Appeal recently ruled to restrict private., will be able to access it on trellis 67 Cal.App.4th 424, 433-34 ; Townsend v. Super good is. Party. ( 1 ) Violation of Civ 158 Cal.App.4th 60, 98 a determination of whether attempt... /Resources 29 0 R Tenant, More Proc., 2025.420 ( a ). about law this pursuant! Make motion for protective order deposition california determination pursuant to a motion for protective order is DENIED to! 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Moves for the members of the opposing party from discovery it is legally entitled to propound discovery on Defendant April. 37 ( a ) ; ( 3 ) Violation of Civ motion on pleading paper Nativi v. Deutsche National... Likely need to file More than once to win your case in Diego. See a motion for protective order Colonial W. Agency ( 2001 ) 87 Cal.App.4th motion for protective order deposition california, 1016. San. Court is in the context of depositions Representing Yourself ( Pro Se ) Colonial. General Motors, LLC 's motion for protective order once to win your case in court files a `` ''... Be personally filed and served no later than the Date set for.. Alleges she was wrongfully terminated from the court b ) ; ( 2 ) Violation of Civ narrowly limited certain... 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