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Does a California Motion for a Protective Order to limit Discovery need a Separate Statement?

Fresno, CA |

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.

Attorney Answers 2


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.

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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.

[In accordance with the Avvo community guidelines, this communication does not constitute "legal advice", nor does it form an attorney-client relationship.]

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