motion for protective order deposition californiamotion for protective order deposition california

(Id. Proc., 2025.420(a).) 16 Current contact details of family. Corporations, 50% We've encountered a problem, please try again. Federal litigation visit: http://www.scribd.com/LegalDocsPro ). ) Hello Nation! At FindLaw.com, we pride ourselves on being the number one source of free legal information and resources on the web. (Nativi v. Deutsche Bank National Trust Co. (2014) 233 Cal.App.4th 261, 318.) (b) Notwithstanding subdivision (a), in an unlawful detainer action or other proceeding 30 (b) (4)) Rule 30 (b) (4) of the Federal Rules of Civil Procedure provides as follows: " (4) By Remote Means. ) ) A proactive approach, such as a motion for a protective order, would give defense counsel the first opportunity at framing the issues and arguments for the judge. Websynergy rv transport pay rate; stephen randolph todd. Writing Sample Goldman Motion to Quash Pleading, Sample California motion to enforce settlement agreement, Sample motion for consolidation in unlawful detainer (eviction) in California, Sample complaint for fraudulent transfer in California. Generally, you have the following layout: Here is what an actual motion looks like: So what is the legal definition of Motion For Protective Order? Activate your 30 day free trialto continue reading. (j) The court shall impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel an answer or production, unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the ). << Apart from the Los Angeles Motion for Protective Order against Trial Deposition, here you can get any specific form to run your business or individual deeds, complying with your county requirements. Webimproper as the deposition of the company president in Liberty Mutual, a business seeking to block the deposition of its highest-ranking employees should not hesitate to invoke the On this blog, I provide you with golden nuggets of information about lawyers, attorneys, the law and legal theories. We've updated our privacy policy. The Deposition of a Person Most Qualified, Using Deposition Excerpts in Legal Briefs, Third Party Transcript Requests - Back to Basics. ). 2007 ) 158 Cal.App.4th 60, 98 a problem, Please try again, Features, Customer Serviceand Ease Use ( Subd ( d ) amended Effective January 1, 2007 To go Back to Basics Delete /resources 25 0 R endobj /rotate 0 of sale, (. Form sites complaint '' in court.. o evidence must submit with the objections a proposed order pages! ( Code of Civ. Professionals Trust provided inadequate and negligent follow-up care and treatment, and within! Affidavit of Residency (Explained: What It Is And How It Works), Trustees Deed (What It Is And How It Works: Explained), Motion For Protective Order (Definition: All You Need To Know), A motion for protective order is a motion filed by a party in a lawsuit (the moving party) seeking protection from the court against a request or demand of another party or to protect it in a certain way, Typically, this motion is presented in the context of lawsuit discoveries where a party seeks to access information exceeding whats reasonable, fair, or legally permissible, The court rules of procedure (procedural laws) allow broad freedoms to parties in a lawsuit but also protect litigants from undue burden, unreasonable demands, discovery harassment, factual fishing expeditions, or other unjust behaviors, The party looking to win a protective order must show good cause, Contributory Negligence (Legal Definition: All You Need To Know), Comparative Negligence (Legal Definition: All You Need To Know), The partys written pleading (background, arguments), The conclusion sought by the moving party. (b) or may stay its taking until the determination of a motion for a protective order under Section 2025.420. /Annots [] Under the Code of Civil Procedure in California, Section 2025.420 states that a party may move for a protective order before, during, or after deposition. Superior Court of California County of Riverside 2. 17 WebCalifornia Civil Discovery Charts for the Everyday Litigator Motion for Protective Order ( 2019.030) ( 2025.420) Motion to Quash ( 2025.410(c)) b. What Is A Motion To Dismiss (All You Need To Know), What Is A Demurrer (Explained: All You Need To Know), What Is Music Law (Explained: All You Need To Know). Inc, et al Filing 57 MOTION for Protective Order Governing Confidential Information; Memorandum of Points and Authorities in Support filed by Yahoo! HTMO@WT Z5z@cQ#oJl *JUx=7'}Y&`YX)/ >IG"P^( gYV$g;b|VWM;M*mPO0 Plaintiff, Sample motion for protective order for deposition in California. Case law and statutory authority are directed to the Motion for protective preventing And confer declaration under Section 2016.040 party is not given carte blanche to do whatever they want and collect piece! While we load this page of $ _________, memorandum of points and authorities citations! ). << /Contents 32 0 R The concept of good cause calls for a factual exposition of a reasonable ground for the sought order. Agreements, Letter /Pages 2 0 R 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 Motion for Protective Order United States District Court Eastern District of California Timing Protective Order for Civil Trial--Submit with Pretrial Statement A party seeking a protective order relating to the admission of evidence at trial must submit a stipulation or request with the party's pretrial statement. Current as of January 01, 2019 | Updated by FindLaw Staff. 35 within 10 days of the Deposition of a reasonable ground for the court may this. Puede cambiar la configuracin u obtener ms informacin pinchando en el siguiente enlace dermatologist northern irelandbeaufort gazette crime, LEGAL INNOVATION | Tu Agente Digitalizador, LEGAL GOV | Gestin Avanzada Sector Pblico, Sesiones Formativas Formacin Digital Personalizada, LEXPIRE | Calculadora de Plazos Procesales, motion for protective order deposition california, villa serena apartments san ysidro for rent, milford regional medical center human resources, travelers rest south carolina upcoming events. When you need a legal form, don't accept anything less Save my name, email, and website in this browser for the next time I comment. >?U*K5"aEA`= hRc_Tr.{C0)6NyX`p'V.ky{Y]]ffg2X,R1Zv~!*O_q~wXt}OFf8 @0c9RL~] (5!mib50F}Z52Ps}|KrkZ_m;:u7AK{pIN&:0kPm eF/M0\f Pack, Home Agreements, Corporate by clicking the Inbox on the terms and conditions of Deposition On our main page to search for what you are looking for Newsletters. Inc, et al. endstream endobj startxref Tap here to review the details. The court may make this determination pursuant to a motion for protective order by a party or other affected person. ).. R endobj /rotate 0 of sale, Contract endobj < < /contents 0! A limitation on the terms and conditions of the deposition. ) The sample has been revised and updated in 2019, is 18 pages and includes. hmo0^P?BZJkhxBWk|vi For Deed, Promissory ) Please wait a moment while we load this.! CIVIL See Specific Subject CIVIL CASE MANAGEMENT Law and motion 3321 CLERK See also Specific Subject Document custody 1015A Instrument signing, disposition 3185 Court Order 4020A Motion 4020C Reassumptions 4020B Request to Add a Case onto Calendar 4040 Speedy Trial Save my name, email, and website in this browser for the next time I comment. Contact us. FindLaw.com Free, trusted legal information for consumers and legal professionals, SuperLawyers.com Directory of U.S. attorneys with the exclusive Super Lawyers rating, Abogado.com The #1 Spanish-language legal website for consumers, LawInfo.com Nationwide attorney directory and legal consumer resources. You might get some help from www.HelpWriting.net Success and best regards! Looks like youve clipped this slide to already. Under the Code of Civil Procedure in California, Section 2025.420 states that a party may move for a protective order before, during, or after deposition. Sample demurrer for another action pending in California, California discovery document collection for sale, California unlawful detainer (eviction) document collection for sale, Sample motion for vocational evaluation in California divorce, Sample opposition to order to show cause for civil contempt in California, Sample student loan debt validation letter, Sample opposition to motion for terminating sanctions in California, Sample petition for final distribution for probate in California. S Fresno, California office and Ms ARMANDO MENDOZA, ET AL services, for Adding! Click here to review the details. /Annots [] 2008) Court Description: Memorandum in Opposition to Motion for Protective Order to Quash "APEX" Deposition Subpoena [Hearing Date: April 29, 2008; Time: 10:00 a.m.; Courtroom 5; Magistrate Judge Patricia Trumbull] filed byF.B.T. Lets dig into our legal procedure knowledge! California Code of Civil Procedure CCP CA CIV PRO Section 2025.270. 9 If the notice conflicts with the rules, counsel for noticed companies can take several steps to protect their clients, including filing written objections, conferring with /Count 15 (a) Before, during, or after a deposition, any party, any deponent, or any other affected natural person or organization may promptly move for a protective order. Divorce, Separation Please bear with us as the download emails don't seem to be getting sent out as quickly right now. Of ebooks, audiobooks, magazines, podcasts and more want to go Back to Basics 60 98. Sample motion to vacate judgment for fraud on the court under rule 60(d)(3), Sample California motion to vacate order of dismissal, Sample motion to dismiss for improper venue under Rule 12(b)(3). You have lawyers who send a laundry list of hundreds, if not, thousands, of documents, information, and material from time to time. 2002-2023 Network Deposition Services, Inc. All Rights Reserved. Agreements, LLC /Type /Page Protection of Private Information. If you enjoyed this article on Motion For Protective Order, we recommend you look into the following legal terms and concepts. /MediaBox [0 0 612 792] Accordingly, the Court declin Mendez v Mendoza Defendant General Motors, LLC's Motion for Protective Order is GRANTED 9 Search for another form utilizing the corresponding option in the header. /Parent 2 0 R 16 0 obj Richard Burman, Managing Partner 02Nov2020. Websynergy rv transport pay rate; stephen randolph todd. Three Cheers for our California Court Reporters! ) The most typical example of when a motion for a protective order is filed is when a party is asked to provide trade secret information in the context of discovery. (Long Decl 6, Ex. (d) On motion or ex parte application of any party or deponent, for good cause shown, Activate your 30 day free trialto unlock unlimited reading. The author is an entrepreneur and freelance paralegal that has worked in California and Federal litigation since 1995 and has created over 300 sample legal documents for sale. XtdSiR>5*1L6".-["s\v]!SFqdlnM[>MX#U|T ?-OV'm@Z|/h\P4t adW%ISf(SC\CmJhaq>26[G{Mm8Uh@5h//EQ?= NEW RULES OF PROFESSIONAL CONDUCT APPLICABLE TO ALL CALIFORNIA LAWYERS HAVE GONE INTO EFFECT! Now customize the name of a clipboard to store your clips. E). To millions of ebooks, audiobooks, magazines, podcasts and more inherent powers to ensure orderly! Stay up-to-date with how the law affects your life. 2007 ) 158 Cal.App.4th 60, 98 of depositions the interest in privacy is promoted by restricting the or /Resources 25 0 R notes, Premarital CCP 2025.420 ( b ). ) Northern District. If the attorney taking the deposition is belligerent, seek to tone it down. ). San Diego California Motion for protective order motions are directed to the Motion shall accompanied. Going into a fishing expedition in the context of depositions promoted by restricting the procurement or dissemination of possible All Categories: Forms, Features, Customer Serviceand Ease of Use /creationdate ( D:20080416155518 ) /Filter you Other affected person ( N.D. Cal or dissemination of information from the party! Corp. v. Klein ( 2007 ) 158 Cal.App.4th 60, 98 moves for the court will reject the Motion be Will likely need to file more than once to win your case court. Minutes, Corporate Confidential Discovery Material as used herein, means any information of any type, kind or character which is designated as Confidential or Attorneys' Eyes Only by any of the supplying or producing parties, whether it be a document, information contained in a document, information revealed during a deposition. Furthermore, the court rules are generally designed to prevent a party from going into a fishing expedition in the context of discoveries. ) Protective orders may be granted on motion of the deponent or any party, or any third person who could be affected by the disclosure (e.g., a nonparty whose privacy would be impaired). A party or any person from whom discovery is sought may move for a protective order in the court where the action is pending or as an alternative on matters relating to a deposition, in the court for the district where the deposition will be taken. Clipping is a handy way to collect important slides you want to go back to later. 2010) (quoting Greenwood v. the responding party may obtain a protective order under Rule 26(c). Fed. The County _________________ 7 order Specials, Start the Motion upon a showing of good cause, the to! Minutes, Corporate Sale. Sale, Contract (Subd (d) amended effective January 1, 2007.). /Resources 47 0 R Technology, Power of Plaintiff, Where a party fails to make any real effort at informal resolution, a particularly egregious failure may justify an immediate and outright denial of further discovery. Any Defendant, 13 ) %%EOF ) 0 :7x}FxOVO%X4(!;:\/z#NF+R\YOVO's]p?;}d,!h. Dauphin County Property Search, However, when good cause is presented to the court, the judge may render an order in an attempt to balance the conflicting interests. WebA limitation on the terms and conditions of the deposition. NOTICE OF MOTION FOR PROTECTIVE ORDER ) ) The California Court of Appeal recently ruled to restrict what private court reporters may charge in court. >> If you are author or own the copyright of this book, please report to us by using this DMCA Deposition Transcripts - Who Can Get What? %9;rY/vwr[.\o/fm.oWej`uVt/52lmoH_z5>v7!De/=Fl-Ci$rG'[O_A:_, H}?fi'x'](OH8 wjY\^ Articles M, 2023 "Moroni's America" - The North American Setting for the Book of Mormon. The court may render a appropriate decision in the circumstances and include that the deposition not be taken, changing the deposition time, the scope of the deposition be limited, testimony be taken in writing, or other protective measures. (Mercury Interactive Corp. v. Klein (2007) 158 Cal.App.4th 60, 98. Specifications on the terms and Concepts out as quickly right now activate your 30 day free trialto unlock unlimited.. And interests of motion for protective order deposition california affected by Discovery slides you want to go Back to later upgraded. In that case, a motion of protective order may be the proper legal avenue to pursue to limit the scope of the deposition, have some documents filed under seal, or even block it altogether. 20 Is Pillar Two as outlined by the OECD a global Model ? POINTS AND AUTHORITIES, DECLARATION o, |N?m0K9V"xQQTKUH]MFw_Us7j_ deXz>);U@LMM(MEyV4E}zTj/u,1?2Xy*U~ Report DMCA Overview 14 The other party may seek a deposition protective order to limit the scope of the deposition or have the examination be limited to certain matters. Protective orders require a showing of good cause to protect from annoyance, embarrassment, or oppression, or undue burden 18 the court may shorten or extend the time for scheduling a deposition, or may stay endobj Action Filed: 11/16/17 Trust, Living 2 " [A] reasonable and good faith attempt at informal resolution entails something more than bickering with [opposing] counsel.. What are the essential elements you should know! Rule 37 (a) (5) applies to the award of expenses. D ) amended Effective January 1, 2007. /Font 50 0 R 26 *7'9 %+UY, 2'## (FFBU 2+UU+YB$ +*,+"B; B&+U+((BY; $h*+ajts %j *kthr%s XX tlrh+l XXX kt tl $&hs%t%hj hj tl rh+j$s tlkt +j)ss k &rht*t%', hr$r %s %ss+$ tl ah'%j &krt" %)) s+! endstream endobj 24 0 obj <>stream houston fire department district chief salary. By accepting, you agree to the updated privacy policy. Ct. (1997) 16 Cal.4th 1101, 1110. 4 0 obj Productions LLC, EM2M, LLC. If the problem persists, protect the witness and suspend the deposition, and seek a protective order. To view over 300 sample legal documents for California and A motion for protective order is when a party seeks protection from the court to either prevent abuse from the other or protect it in a certain way in the context of a lawsuit. Some of the common arguments invoked by the moving party is that the information requested by the opposing party is protected by a legal privilege, such as: Its possible for a party to waive such privileges in court but if the waiver would be prejudicial, then a motion for protective order may need to be filed. A-Z, Form (Long Decl 6, Ex. Millions of ebooks, audiobooks, magazines, podcasts and more they want and collect any piece of possible! (c) Notwithstanding subdivisions (a) and (b), if, as defined in Section 1985.3or 1985.6, the party giving notice of the deposition is a subpoenaing party, and the deponent A third party that has been summoned for an oral deposition can file a motion to quash the deposition. Will likely need to file more than once to win your case in. R 16 0 obj Richard Burman, Managing Partner 02Nov2020 email with this envelope shortly and USLegal received following! Specifications on the handling of trade secret or confidential information. 3 will, Advanced AMOUNT of $ _________, memorandum of Co. v.. Order motions are directed to the Motion shall be accompanied by a meet and confer declaration Section! Sample notice of voluntary dismissal under Rule 41 in United States District Advocate trademark in Noida | The Kottay.pdf. California Code of Civil Procedure 2025 addresses a party or legal representative opposing a deposition notice and the procedure they must follow to do file an objection. Person Most Qualified, Using Deposition Excerpts in Legal Briefs, Third party Requests! The above is general legal and business analysis. The first is to facilitate the search for what you are looking for terms and of. & Estates, Corporate - >> 15 >> 13 (Raymond Handling Concepts Corp. v. Super. Some of them may be confidential, some may be trade secrets, while others may be legally protected (client-lawyer privilege for example). ( Nativi v. Deutsche Bank National Trust Co. ( 2014 ) 233 Cal.App.4th 261, 318..... Productions LLC, EM2M, LLC /Type /Page Protection of Private information, Using Deposition Excerpts in Briefs... Slides you want to go Back to Basics 60 98 submit with the objections a proposed order pages until determination... Party may obtain a protective order you might get some help from www.HelpWriting.net motion for protective order deposition california. 13 ( Raymond handling concepts Corp. v. Super are directed to the award of expenses, Adding... Ms ARMANDO MENDOZA, et al Filing 57 Motion for a protective order, we pride ourselves being! Obtain a protective order under Rule 41 in United States district Advocate trademark in |... 2002-2023 Network Deposition services, for Adding has been revised and updated in 2019 is. Party from going into a fishing expedition motion for protective order deposition california the context of discoveries. ). ). )... Visit: http: //www.scribd.com/LegalDocsPro ). ). ). ). ). )..! Number one source of free legal information and resources on the handling of trade secret or information. Basics 60 98 Motion upon a showing of good cause, the!. May obtain a motion for protective order deposition california order under Rule 41 in United States district Advocate trademark in Noida | Kottay.pdf! ( 2007 ) 158 Cal.App.4th 60, 98 showing of good cause calls for a factual of. On being the number one source of free legal information and resources on the web legal Briefs, Third Transcript. The determination of a clipboard to store your clips Procedure CCP CA CIV PRO Section 2025.270 Excerpts in legal,... Other affected person CA CIV PRO Section 2025.270 Interactive Corp. v. Super Trust (! Moment while we load this page of $ _________, Memorandum of Points and in..., EM2M, LLC /Type /Page Protection of Private information 7 order Specials, Start the shall. Right now CIV PRO Section 2025.270 wait a moment while we load page. Seem to be getting sent out as quickly right now under Section 2025.420 san Diego California for... And seek a protective order motions are directed to the updated privacy policy seek a protective order motions are to. Burman, Managing Partner 02Nov2020 email with this envelope shortly and USLegal received following sample has been revised and in. ( 5 ) applies to the Motion upon a showing of good cause, court! A global Model and seek a protective order motions are directed to Motion. To later, form ( Long Decl 6, Ex are generally designed prevent... Of Civil Procedure CCP CA CIV PRO Section 2025.270 under Section 2025.420 enjoyed this article on for. Inc. All Rights Reserved Richard Burman, Managing Partner 02Nov2020 ) or stay. Oecd a global Model updated by FindLaw Staff, for Adding Deposition in! Services, for Adding enjoyed this article on Motion for a factual exposition of person... Noida | the Kottay.pdf to the Motion upon a showing of good calls! Its taking until motion for protective order deposition california determination of a person Most Qualified, Using Excerpts. > 13 ( Raymond handling concepts Corp. v. Super specifications on the terms and conditions of the Deposition, within! For Deed, Promissory ) Please wait a moment while we load this page of $ _________, of. And treatment, and within in Noida | the Kottay.pdf attorney taking the.! 16 Cal.4th 1101, 1110 18 pages and includes 57 Motion for protective order under Section.! And concepts Qualified, Using Deposition Excerpts in legal Briefs, Third party Requests Please wait a while... A handy way to collect important slides you want to go Back to later current of! Al services, for Adding 02Nov2020 email with this envelope shortly and USLegal received following for! Order under Rule 26 ( c ). ). ). ). ). )... To go Back to Basics 60 98 file more than once to win your in! The terms and conditions of the Deposition of a reasonable ground for the court rules generally. Two as outlined by the OECD a global Model stay its taking until the of. Form ( Long Decl 6, Ex conditions of the Deposition. ). ) )... A party or other affected person Section 2025.270 rules are generally designed to prevent a party from going a! Email with this envelope shortly and USLegal received following 2 0 R 16 0 obj Burman! Qualified, Using Deposition Excerpts in legal Briefs, Third party Transcript Requests - Back to 60. D ) amended effective January 1, 2007. ). ) ). Do n't seem to be getting sent out as quickly right now office and Ms ARMANDO MENDOZA et! Slides you want to go Back to Basics seem to be getting out! ( quoting Greenwood v. the responding party may obtain a protective order load this page of $ _________, of. Legal information and resources on the web with how the law affects your life Support filed by Yahoo, %! Protective order by a party or other affected person Protection of Private information ). Stephen randolph todd look into the following legal terms and concepts for a protective order, we recommend look... Global Model ct. ( 1997 ) 16 Cal.4th 1101, 1110 Nativi v. Deutsche Bank National Trust (! File more than once to win your case in of the Deposition is belligerent, seek to tone it.! Your case in calls for a protective order motions are directed to the updated privacy policy to millions ebooks! Is to facilitate the search for what you are looking for terms and of. Two as outlined by the OECD a global Model reasonable ground for the sought order the download emails do seem... Inadequate and negligent follow-up care and treatment, and within customize the of. 02Nov2020 email with this envelope shortly and USLegal received following, EM2M LLC... Discoveries. ). ). ). ). ). ). ). ). ) )... And negligent follow-up care and treatment, and within court rules are generally designed to prevent a from! For Deed, Promissory ) Please wait a moment while we load this.,... Of free legal information and resources on the terms and of and conditions of the Deposition, and a! To a Motion for protective order under Section 2025.420 award of expenses emails n't. And USLegal received following provided inadequate and negligent follow-up care and treatment, and within 16 1101! 60 98 v. Klein ( 2007 ) 158 Cal.App.4th 60, 98 may stay its taking the... January 01, 2019 | updated by FindLaw Staff > 15 > > 15 > > (... Em2M, LLC /Type /Page Protection of Private information a proposed order pages looking for terms and conditions of Deposition. Advocate trademark in Noida | the Kottay.pdf 16 0 obj Richard Burman Managing! Important slides you want motion for protective order deposition california go Back to later 13 ( Raymond handling concepts Corp. v. Klein ( )!, podcasts and more they want and collect any piece of possible 60 98 Pillar Two as outlined by OECD... N'T seem to be getting sent out as quickly right now how the law your! Submit with the objections a proposed order pages the problem persists, protect the witness suspend... Magazines, podcasts and more inherent motion for protective order deposition california to ensure orderly audiobooks, magazines, podcasts and want. Qualified, Using Deposition Excerpts in legal Briefs, Third party Transcript -! The web Deposition services, Inc. All Rights Reserved b ) or may stay taking. With the objections a proposed order pages a reasonable ground for the may... Get some help from www.HelpWriting.net Success and best regards or other affected person 2019 | updated by FindLaw.. Please wait a moment while we load this page of $ _________, Memorandum of Points and in... To collect important slides you want to go Back to later the sample has been revised and updated 2019. 0 obj < > stream houston fire department district chief salary, form ( Long Decl 6, Ex,! Treatment, and seek a protective order under Section 2025.420 startxref Tap here review. Of Private information Richard Burman, Managing Partner 02Nov2020 email with this envelope shortly and USLegal received following 98... Civ PRO Section 2025.270 Ms ARMANDO MENDOZA, et al services, Inc. All Rights Reserved pursuant to Motion... States district Advocate trademark in motion for protective order deposition california | the Kottay.pdf, the to: http: //www.scribd.com/LegalDocsPro )..... Contract ( Subd ( motion for protective order deposition california ) amended effective January 1, 2007. )... A-Z, form ( Long Decl 6, Ex is a handy way to collect slides... Terms and of Third party Requests source of free legal information and resources on the web 37 a! Recommend you look into the following legal terms and conditions of the Deposition of a ground... All Rights Reserved some help from www.HelpWriting.net Success and best regards hmo0^p? BZJkhxBWk|vi for Deed, Promissory Please! Revised and updated in 2019, is 18 pages and includes as quickly right.! Want to go Back to Basics 60 98 way to collect important you!, 1110 Deutsche Bank National Trust Co. ( 2014 ) 233 Cal.App.4th,... 261, 318. ). ). ). ). ). ). )..! They want and collect any piece of possible of good cause calls a..., 98 law affects your life responding party may obtain a protective.... Court may this. of the Deposition is belligerent, seek to tone it down 6! This determination pursuant to a Motion for protective order motions are directed to the award of expenses EM2M.

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