Sample Opposition to Motion for Protective Order for Documents in California

Sample Opposition to Motion for Protective Order for Documents in California. This sample opposition to a motion for a protective order regarding requests for production of documents in California is filed on the grounds that (1) the moving party has failed to meet their burden of showing good cause for the protective order, (2) the documents requested are clearly relevant to the issues involved in this case they relate to the claim or defense of the moving party and therefore meet the relevancy standard imposed by Code of Civil Procedure § 2017.010, (3) the requests for production of documents are not overbroad and oppressive or vague and ambiguous, and (4) that the requests for production of documents are not excessive.  The opposition also requests sanctions pursuant to Code of Civil Procedure section 2031.060(h) on the grounds that the moving party failed to make a reasonable good faith effort to meet and confer before filing the motion for a protective order. The sample has been