Model Protective Order All counsel requesting that Judge Cox enter a protective order to preserve the confidentiality of materials disclosed in discovery must adopt, in whole or in part, the Model Protective Order. Tags: "Motion for Protective Order" , "Protective Order" , Abuse , Sanctions B. URCP 37. Among the topics addressed here are blanket orders, stipulated orders, and designating discovery for attorney eyes only. Before filing a motion for extraordinary discovery, a motion to compel discovery or a motion for a protective order, the parties must meet (in person or by telephone) to try to resolve or narrow the issues without court involvement. PROTECTIVE ORDERS PROHIBITING DISSEMINATION OF DISCOVERY INFORMATION: THE FIRST AMENDMENT AND GOOD CAUSE Federal Rule of Civil Procedure 26(c)t authorizes courts to order parties to litigation not to disseminate information obtained in civil dis-covery.2 Rule 26(c) requires a party seeking this type of order to show A responding party to a discovery dispute may file a motion with the court asking for a protective order, which will then alleviate that party from having to respond to a discovery question or demand. Discovery Motion Procedures. Forms of Discovery. Back to Main Page / Back to List of Rules. answer interrogatories, answer deposition questions on a subject, provide documents responsive to a request for production of documents, to allow someone to inspect premises, or to participate in a forensic medical exam), from having to provide that discovery. There may be significant benefits to filing such a protective motion, including: Discovery demands may … A protective order from discovery protects the person who would otherwise have to provide discovery (e.g. The provisions of rule 1.380(a)(4) apply to the award of expenses incurred in relation to the motion. Less often, a temporary restraining order issued to prohibit domestic violence is referred to as a protective order. 1. The protective orders discussed in this pocket guide are different from sealing orders that protect the courts' own records and protective orders that protect information from discovery. The court in which the criminal action is pending may, upon motion of either party, or of any affected person, or upon determination of a motion of either party for an order of discovery, or upon its own Protective Orders . On motion to compel discovery or for a protective order, the party from whom discovery is sought must show that the information is not reasonably accessible because of undue burden or cost. Discovery; protective orders * § 240.50 Discovery; protective orders. Meet and Confer. A protective order is commonly used to protect a party or witness from unreasonable or invasive discovery requests (for example, harassing questions in a deposition, or an unnecessary medical examination). If the motion for a protective order is denied in whole or in part, the court may, on such terms and conditions as are just, order that any party or person provide or permit discovery. 1. Rule 166b. Forms and Scope of Discovery; Protective Orders; Supplementation of Responses (1990) TEXT. HINT: See CEB California Civil Discovery Practice 4 th edition Section 15.59 for an extensive discussion on Protective Order and CEB Section 6.142-6.144 for a sample motion for protective order. Statement of Discovery Issues.

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