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 SPECIAL INTERROGATORIES;
)
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 )
)
18

19 TO: _____________________________ AND THEIR ATTORNEY OF

20
RECORD HEREIN:
21
PLEASE TAKE NOTICE that on ____________, 20___, at _______.m. or as soon thereafter
22
as the matter may be heard, in Department ________ of the above-entitled court, located at
23

24 __________________________, ___________________________will and hereby do move this

25 Court:
26
1. For a protective order that the moving party need not answer interrogatories 36
27
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
 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. For a protective order that the moving party need not answer interrogatories LIST
4
NUMBERS HERE of Set One, on the grounds that unless a protective order is issued the moving
5

6
party will suffer unwarranted annoyance, embarrassment, or oppression, or undue burden and

7 expense pursuant to Code of Civil Procedure 2030.090(b) and0 Code of Civil Procedure

8 2030.090(b)(1); and
9
3. For an order of sanctions as against ______________________________, in the
10
amount of $____________ for their blatant failure and refusal to meet and confer in a reasonable
11
good faith effort to reach an informal resolution of this matter.
12

13 This motion is brought pursuant to Code of Civil Procedure 2016.010 et seq., on the

14 grounds that ____________ propounded more than 35 specially prepared interrogatories without
15
including the supporting declaration required by law, and has propounded ___ specially prepared
16
interrogatories that clearly do not relate to the claim or defense of the party seeking discovery or of
17
any other party to the action as required by Code of Civil Procedure 2017.010, and on the further
18

19 grounds that the interrogatories are unduly burdensome and oppressive.

20 The moving party further requests pursuant to Code of Civil Procedure 2030.090(d), the
21
sum of $___________ in sanctions against _____________________.
22
This Motion is made upon the grounds that ____________ the moving party has made
23
reasonable good faith efforts to reach an informal resolution of this matter without the need for
24

25 judicial intervention but ___ has rebuffed all efforts.

26 This motion is based upon this notice, the attached memorandum of points and authorities,
27
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
 1 be presented to the Court by _________________ at the time of the hearing.
2
Be sure to modify these paragraphs to suit your individual
3

4 situation. Do NOT just use the wording here unless it definitely applies
5
to your particular situation. Do NOT ask for attorneys fees if you are
6

7 not represented by an attorney.

8

10
Dated________________ _______________________________________________
ANY ATTORNEY OR PARTY
11

12 To purchase the entire 15 page document visit:

13

14
https://legaldocspro.myshopify.com/products/sample-motion-for-
15
protective-order-regarding-interrogatories-for-california
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NOTICE OF MOTION AND MOTION FOR PROTECTIVE ORDER-INTERROGATORIES