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 SPECIAL INTERROGATORIES;
13 ) AND 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 To subscribe to my FREE weekly legal newsletter visit

21

22
http://legaldocspro.net/newsletter.htm and enter your e-mail address.
23
To view over 300 sample legal documents sold by LegalDocsPro
24

25 visit: http://www.scribd.com/LegalDocsPro
26
Be sure to remove this notice and all other notices before using
27

28 this document.
- 1 -

OPPOSITION TO MOTION FOR PROTECTIVE ORDER-INTERROGATORIES

 1 NAME AND PARTY CAPACITY herein submits its Opposition to the motion for a
2 protective order and for sanctions filed by NAME AND PARTY CAPACITY on the grounds that (1)
3
the moving party has failed to meet their burden of showing good cause for the protective order, (2)
4
the information sought by the interrogatories is clearly relevant to the issues involved in this case as it
5

6
relates to the claim or defense of the moving party and therefore meets the relevancy standard

7 imposed by Code of Civil Procedure 2017.010, (3) that the interrogatories are not overbroad and

8 oppressive or vague and ambiguous, and (4) that the interrogatories are not excessive and were
9
served with a valid, executed declaration for additional discovery in compliance with Code of Civil
10
Procedure 2030.040(a), 2030.050.
11
NAME AND PARTY CAPACITY further requests the sum of $____ in sanctions against the
12

13 moving party pursuant to Code of Civil Procedure 2030.090 on the grounds that the moving party

14 filed their motion for a protective order without a showing of good cause.
15
The Opposition shall be based on this Opposition, the attached memorandum of points and
16
authorities, the declaration of ___________and exhibits attached thereto, on the complete files and
17
records of this action, and on such other oral and/or documentary evidence as may be presented at the
18

19 hearing on the Motion.

20 Dated________________ _______________________________________________
ANY ATTORNEY OR PARTY
21

22
Be sure to modify these paragraphs to suit your individual
23

24 situation. Do NOT just use the wording here unless it definitely applies
25

26 to your particular situation. Remember that YOUR OPPOSITION

27
MUST BE SERVED AND FILED AT LEAST NINE (9) COURT DAYS
28

- 2 -

OPPOSITION TO MOTION FOR PROTECTIVE ORDER-INTERROGATORIES

 1 BEFORE THE HEARING. Court days means Monday through
2

3
Friday, except for Court holidays. You should serve your opposition by
4
personal delivery or overnight mail. See Code of Civil Procedure
5

6 section 1005 for more details.

7
To purchase the entire 15 page document visit:
8

9
https://legaldocspro.myshopify.com/products/sample-
10

11 opposition-to-motion-for-protective-order-for-interrogatories-
12

13 in-california
14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

- 3 -

OPPOSITION TO MOTION FOR PROTECTIVE ORDER-INTERROGATORIES