California Rules of Court 3.1345 makes it sound like a Motion for a Protective Order would need a Separate Statement since I am trying to limit a discovery request. This is a limited jurisdiction case and the Defendant asked for considerably more than 35 total discovery requests without a motion for additional discovery or a declaration of additional discovery so I am filing a Motion for Protective Order. Thanks.
Lawsuit / Dispute Attorney
An easier way to address this situation might just be to respond to the first 35 requests and object to the rest on the grounds that they exceed the permissible amount.
Personal Injury Lawyer
Usually, if you call the other side and point out the error of their ways, they should withdraw the request or modify it to conform to the applicable laws.
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