[COURT NAME]
[COUNTY], [STATE]

[PLAINTIFF NAME], )
Plaintiff, ) Case No. [CASE NUMBER]
v. )
[DEFENDANT NAME], )
Defendant. )

MOTION FOR PROTECTIVE ORDER

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 regarding [SPECIFY DISCOVERY OR DEPOSITION].

MEMORANDUM OF POINTS AND AUTHORITIES

I. Introduction

Good cause exists to protect [MOVING PARTY] and [NONPARTY] from undue burden, annoyance, and disclosure of confidential information.

II. Background

• Discovery at issue: [REQUESTS/DEPOSITION TOPICS]
• Dates served/noticed: [DATE]
• Concerns: [CONFIDENTIALITY, PRIVILEGE, BURDEN, OR HARASSMENT]

III. Meet and Confer Efforts

[DESCRIBE MEET-AND-CONFER EFFORTS AND OUTCOME.]

IV. Legal Standard

Courts may issue protective orders to prevent annoyance, embarrassment, oppression, or undue burden or expense. The moving party must show good cause and propose reasonable limitations.

V. Argument

A. The requested discovery is overbroad or unduly burdensome.
[Explain scope and burden.]

B. The discovery seeks confidential or privileged information.
[Describe sensitive information and propose protections.]

C. A tailored protective order balances interests.
[Propose limits, such as time, scope, method, or confidentiality designation.]

VI. Requested Relief

[MOVING PARTY] respectfully requests that the Court:
1. Limit discovery to [SPECIFIC LIMITS].
2. Enter a confidentiality order covering [CATEGORIES].
3. Set conditions for deposition or production, including [TIME LIMITS/LOCATION/METHOD].
4. Grant any other relief the Court deems just.

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].

text
______________________________
[ATTORNEY NAME]

[PROPOSED] ORDER

The Court, having considered [MOVING PARTY]'s Motion for Protective Order, ORDERS as follows:
1. Discovery is limited to [SPECIFIC LIMITS].
2. A confidentiality order is entered as described above.
3. Any deposition shall proceed under the following conditions: [CONDITIONS].

IT IS SO ORDERED.

Dated: [DATE]

__________________________________
[JUDGE NAME]
[STATE] Judge