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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 _________________

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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 )
)
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OPPOSITION TO MOTION FOR PROTECTIVE ORDER-REQUESTS FOR ADMISSION


1 Be sure to remove this notice and all other notices before using
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this document.
4 NAME AND PARTY CAPACITY herein submits its Opposition to the motion for a
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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)
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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
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overbroad and oppressive or vague and ambiguous, and (4) the requests for admission are not
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excessive.
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NAME AND PARTY CAPACITY further requests the sum of $____ in sanctions against the
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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
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reasonable good faith effort to meet and confer.
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The Opposition shall be based on this Opposition, the attached memorandum of points and
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authorities, the declaration of ___________and exhibits attached thereto, on the complete files and
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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.


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Dated________________ _______________________________________________
24 ANY ATTORNEY OR PARTY

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26 Be sure to modify these paragraphs to suit your individual


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situation. Do NOT just use the wording here unless it definitely applies
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OPPOSITION TO MOTION FOR PROTECTIVE ORDER-REQUESTS FOR ADMISSION


1 to your particular situation. Remember that YOUR OPPOSITION
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MUST BE SERVED AND FILED AT LEAST NINE (9) COURT DAYS
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BEFORE THE HEARING. Court days means Monday through
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6 Friday, except for Court holidays. You should serve your opposition by
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personal delivery or overnight mail. See Code of Civil Procedure
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9 section 1005 for more details.


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opposition-to-motion-for-protective-order-for-admissions-in-
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16 california
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OPPOSITION TO MOTION FOR PROTECTIVE ORDER-REQUESTS FOR ADMISSION