[COURT NAME]
[DIVISION] DIVISION

[PLAINTIFF NAME(S)], §
§
Plaintiff[s], §
§ CIVIL ACTION NO. [CASE NO.]
v. §
§
[DEFENDANT NAME(S)], §
§
Defendant[s]. §
________________________________________________§______________________________________________

[MOVING PARTY] MOTION FOR PROTECTIVE ORDER
________________________________________________________________________________________________

[// GUIDANCE: Insert any required local-rule header language here.]

NOTICE OF MOTION AND MOTION

PLEASE TAKE NOTICE that on [HEARING DATE] at [TIME], or as soon thereafter as counsel may be heard, [MOVING PARTY] will and hereby does move the Court for a protective order under Fed. R. Civ. P. 26(c) to protect against [UNDUE BURDEN/CONFIDENTIALITY/PRIVILEGE/ANNOYANCE/OPPRESSION].

This Motion is based on the accompanying memorandum, declarations, exhibits, the pleadings on file, and such other argument or evidence as may be presented.

MEMORANDUM OF POINTS AND AUTHORITIES

I. Introduction

[Briefly explain the discovery request at issue and why protection is warranted.]

II. Discovery at Issue

• Discovery served: [DATE].
• Requests at issue: [RFP Nos. __ / Deposition Notice / Subpoena].
• Response deadline: [DATE].

III. Meet-and-Confer Efforts

• Meet-and-confer letter sent: [DATE].
• Conference(s) held: [DATE/TIME], by [phone/video/in person].
• Issues narrowed to: [LIST].

[// GUIDANCE: Include any required certification per local rule.]

IV. Legal Standard

The Court may issue a protective order to protect a party or person from annoyance, embarrassment, oppression, or undue burden or expense. Fed. R. Civ. P. 26(c). The moving party must show good cause.

V. Argument

A. The discovery is unduly burdensome or disproportionate.
[Explain burden, cost, volume, and lack of proportionality.]

B. The discovery seeks privileged or protected information.
[Explain privilege or work product concerns; propose alternatives.]

C. The discovery seeks confidential or sensitive information.
[Explain need for confidentiality protections or limits.]

D. A narrower alternative is appropriate.
[Offer narrowed scope, phased discovery, or protective order terms.]

VI. Requested Relief

[MOVING PARTY] respectfully requests that the Court:
1. Issue a protective order limiting discovery as follows: [LIMITATIONS].
2. Prohibit or limit [DEPOSITION/REQUEST] to [DATE RANGE/CUSTODIANS/TOPICS].
3. Require a confidentiality protective order for production.
4. Award expenses under Rule 26(c)(3) and 37(a)(5), if appropriate.

CONCLUSION

For the foregoing reasons, the Court should grant the Motion for Protective Order.

Respectfully submitted,

text
Dated: [DATE]

______________________________
[ATTORNEY NAME]
[LAW FIRM]
[ADDRESS]
[PHONE]
[EMAIL]
Attorney for [MOVING PARTY]

CERTIFICATE OF SERVICE

I certify that on [DATE], I served the foregoing Motion for Protective Order on all counsel of record via [METHOD OF SERVICE] in compliance with Fed. R. Civ. P. 5.

text
______________________________
[ATTORNEY NAME]

[PROPOSED] ORDER

The Court, having considered [MOVING PARTY]'s Motion for Protective Order and any opposition, ORDERS as follows:
1. The Motion is GRANTED.
2. Discovery is limited as follows: [LIMITATIONS].
3. [OPPOSING PARTY] shall comply with this Order by [DATE].

IT IS SO ORDERED.

Dated: [DATE]

______________________________________
[JUDGE NAME]
United States District Judge