The only rule concerning protective orders in Texas Another Motion to Compel Financials (more recent version) [Select here] Protective Order from Second Trial Deposition [Select here] Prevent Expert from Suggesting Victim is Malingering or Lying [Select here] Frey-Reed Motion/Expert Financials: We won this motion, kicking out defendant's only expert in …
R. Civ. If conferring with opposing counsel does not result in a proper 30(b)(6) notice, then moving for a protective order under Rule 26(c) is the only reasonable option. After his rant, I said to him that “You Need to file a motion for a protective order.” It was clear to me that the discovery was retaliatory, either because the case didn’t settle the week before at mediation, or that the opposing counsel was a nut job, or perhaps a little of both. Plaintiff, Richard Gilliand, by and through his undersigned counsel, files this Motion to Quash and/or for Protective Order with respect to a deposition noticed by Defendants on Friday, October 23, 2015, for Tuesday, October 27, 2015, at 6:30 p.m.
No. If you are in an ongoing deposition that has become oppressive, is being conducted in bad faith, or involves other forms of improper conduct, moving for a protective order may be the only way to stop ongoing questioning and require the court reporter to suspend the deposition. 20 Massachusetts Avenue NW Washington, D.C. 20530 Tel: (202) 616-5084 Fax: (202) 616-8470 andrew.warden@usdoj.gov Attorneys for the United States of America UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WASHINGTON SULEIMAN ABDULLAH SALIM, et al., Plaintiffs, v. JAMES E. MITCHELL and JOHN JESSEN, Defendants.
The party or other person relying on the material must file only the germane portion of it as an exhibit or attachment to the motion, response or reply.
Opposition to Motion for Protective Order United States District Court District of Massachusetts Timing Local Discovery Motion Briefing Schedule. Sanctions may include any of the orders listed in Rule 37(b)(2)(A)(i)—(vi). Before concluding with a “Model Protective Order,” this paper provid esan outline of general considerations to be made when preparing a protective order. The grounds for a motion for a protective order for a deposition are that the moving party will suffer unwarranted annoyance, embarrassment, or oppression, or undue burden and expense if the court does not grant the motion for the protective order. A failure described in Rule 37(d)(1)(A) is not excused on the ground that the discovery sought was objectionable, unless the party failing to act has a pending motion for a protective order under Rule 26(c). I HEREBY CERTIFY that a true and correct copy of the foregoing Objection, Motion To Quash And/Or Motion For Protective Order has been served via fax and/or U.S. Mail this 9th day of February, 2007 to: Jonathan E. Altman, Esq., Munger, Tolles & Olson LLP, 355 South Grand Avenue, 35 th Floor, Los Angeles, CA 90071; Katherine W. Ezell, Esq., 2:15-CV-286-JLQ MOTION BY THE UNITED STATES FOR A PROTECTIVE ORDER … 4 These documents should be produced and Plaintiff should have the right to question the Defendants about these documents. Protection of Private Information. (3) Types of Sanctions. JOINT MOTION FOR ENTRY OF STIPULATED PROTECTIVE ORDER Pursuant to Rule 26(c) of the Federal Rules of Civil Procedure, the parties in the above- captioned matter respectfully submit this Joint Motion for Entry of Stipulated Protective Order (attached as Exhibit A hereto). P. 30(d), to suspend the deposition for purposes of seeking a court order to terminate or limit the deposition.