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    Sample Opposition To Motion For Protective Order For Admissions in California

    Uploaded by

    Stan Burman
    This sample opposition to a motion for a protective order for requests for admission in California is filed on the grounds that (1) the moving party has failed to meet their burden of showing good cause for the protective order, (2) the requests for admission are clearly relevant to triable issues of material fact involved in this case they relate to the claim or defense of the moving party and therefore meets the relevancy standard imposed by Code of Civil Procedure § 2017.010, (3) that the requests for admission are not overbroad and oppressive or vague and ambiguous, and (4) the requests for admission are not excessive. The opposition also requests sanctions pursuant to Code of Civil Procedure section 2033.080(d) on the grounds that the moving party filed their motion for a protective order without a showing of good cause or making a reasonable good faith effort to meet and confer. The sample is 15 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. The author is an entrepreneur and freelance paralegal that has worked in California and Federal litigation since 1995 and has created over 300 sample legal documents for sale. Note that the author is NOT an attorney and no guarantee or warranty is provided.

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    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd

    Sample Opposition To Motion For Protective Order For Admissions in California

    Uploaded by

    Stan Burman
    598 views3 pages
    This sample opposition to a motion for a protective order for requests for admission in California is filed on the grounds that (1) the moving party has failed to meet their burden of showing good cause for the protective order, (2) the requests for admission are clearly relevant to triable issues of material fact involved in this case they relate to the claim or defense of the moving party and therefore meets the relevancy standard imposed by Code of Civil Procedure § 2017.010, (3) that the requests for admission are not overbroad and oppressive or vague and ambiguous, and (4) the requests for admission are not excessive. The opposition also requests sanctions pursuant to Code of Civil Procedure section 2033.080(d) on the grounds that the moving party filed their motion for a protective order without a showing of good cause or making a reasonable good faith effort to meet and confer. The sample is 15 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. The author is an entrepreneur and freelance paralegal that has worked in California and Federal litigation since 1995 and has created over 300 sample legal documents for sale. Note that the author is NOT an attorney and no guarantee or warranty is provided.

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    Sample Opposition to Motion for Protective Order for Admissions in California

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    This sample opposition to a motion for a protective order for requests for admission in California is filed on the grounds that (1) the moving party has failed to meet their burden of showing good cause for the protective order, (2) the requests for admission are clearly relevant to triable issues of material fact involved in this case they relate to the claim or defense of the moving party and therefore meets the relevancy standard imposed by Code of Civil Procedure § 2017.010, (3) that the requests for admission are not overbroad and oppressive or vague and ambiguous, and (4) the requests for admission are not excessive. The opposition also requests sanctions pursuant to Code of Civil Procedure section 2033.080(d) on the grounds that the moving party filed their motion for a protective order without a showing of good cause or making a reasonable good faith effort to meet and confer. The sample is 15 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. The author is an entrepreneur and freelance paralegal that has worked in California and Federal litigation since 1995 and has created over 300 sample legal documents for sale. Note that the author is NOT an attorney and no guarantee or warranty is provided.

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
    598 views3 pages

    Sample Opposition To Motion For Protective Order For Admissions in California

    Uploaded by

    Stan Burman
    This sample opposition to a motion for a protective order for requests for admission in California is filed on the grounds that (1) the moving party has failed to meet their burden of showing good cause for the protective order, (2) the requests for admission are clearly relevant to triable issues of material fact involved in this case they relate to the claim or defense of the moving party and therefore meets the relevancy standard imposed by Code of Civil Procedure § 2017.010, (3) that the requests for admission are not overbroad and oppressive or vague and ambiguous, and (4) the requests for admission are not excessive. The opposition also requests sanctions pursuant to Code of Civil Procedure section 2033.080(d) on the grounds that the moving party filed their motion for a protective order without a showing of good cause or making a reasonable good faith effort to meet and confer. The sample is 15 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. The author is an entrepreneur and freelance paralegal that has worked in California and Federal litigation since 1995 and has created over 300 sample legal documents for sale. Note that the author is NOT an attorney and no guarantee or warranty is provided.

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
    of 3

    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 of _________________

    10

    11 Any Plaintiff, ) Case No.


    )
    12 Plaintiff, ) OPPOSITION TO MOTION FOR PROTECTIVE
    vs. ) ORDER FOR REQUESTS FOR ADMISSION AND
    13 ) FOR SANCTIONS; MEMORANDUM OF POINTS
    ) AND AUTHORITIES; DECLARATION OF
    14 Any Defendants, and DOES 1-5, inclusive, ) _________; EXHIBITS
    )
    15 Defendants. ) DATE:
    ) TIME:
    16 ) DEPT:
    )
    17 )
    )
    18 )
    )
    19

    20

    21 To subscribe to my FREE weekly legal newsletter visit


    22
    http://legaldocspro.net/newsletter.htm and enter your e-mail address.
    23

    24 To view over 300 sample legal documents sold by LegalDocsPro


    25

    26
    visit: http://www.scribd.com/LegalDocsPro
    27

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    - 1 -

    OPPOSITION TO MOTION FOR PROTECTIVE ORDER-REQUESTS FOR ADMISSION


    1 Be sure to remove this notice and all other notices before using
    2

    3
    this document.
    4 NAME AND PARTY CAPACITY herein submits its Opposition to the motion for a
    5
    protective order and for sanctions filed by NAME AND PARTY CAPACITY on the grounds that (1)
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    the moving party has failed to meet their burden of showing good cause for the protective order, (2)
    7

    8
    the requests for admission are clearly relevant to triable issues of material fact involved in this case

    9 they relate to the claim or defense of the moving party and therefore meets the relevancy standard

    10 imposed by Code of Civil Procedure 2017.010, (3) that the requests for admission are not
    11
    overbroad and oppressive or vague and ambiguous, and (4) the requests for admission are not
    12
    excessive.
    13
    NAME AND PARTY CAPACITY further requests the sum of $____ in sanctions against the
    14

    15 moving party pursuant to Code of Civil Procedure 2033.080(d) on the grounds that the moving

    16 party filed their motion for a protective order without a showing of good cause or making a
    17
    reasonable good faith effort to meet and confer.
    18
    The Opposition shall be based on this Opposition, the attached memorandum of points and
    19
    authorities, the declaration of ___________and exhibits attached thereto, on the complete files and
    20

    21 records of this action, and on such other oral and/or documentary evidence as may be presented at the

    22 hearing on the Motion.


    23
    Dated________________ _______________________________________________
    24 ANY ATTORNEY OR PARTY

    25

    26 Be sure to modify these paragraphs to suit your individual


    27
    situation. Do NOT just use the wording here unless it definitely applies
    28

    - 2 -

    OPPOSITION TO MOTION FOR PROTECTIVE ORDER-REQUESTS FOR ADMISSION


    1 to your particular situation. Remember that YOUR OPPOSITION
    2

    3
    MUST BE SERVED AND FILED AT LEAST NINE (9) COURT DAYS
    4
    BEFORE THE HEARING. Court days means Monday through
    5

    6 Friday, except for Court holidays. You should serve your opposition by
    7
    personal delivery or overnight mail. See Code of Civil Procedure
    8

    9 section 1005 for more details.


    10

    11 To purchase the entire 15 page document visit:


    12
    https://legaldocspro.myshopify.com/products/sample-
    13

    14
    opposition-to-motion-for-protective-order-for-admissions-in-
    15

    16 california
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    - 3 -

    OPPOSITION TO MOTION FOR PROTECTIVE ORDER-REQUESTS FOR ADMISSION

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