Discovery Protective Orders

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Discovery Protective Orders
Protective orders are obtained by applying to the court, by written motion and notice of hearing, for relief from discovery that is abusive or improper. The objective is to show "good cause" why the court should intervene and prevent or stop the discovery being requested.
Good Cause for Protection
The discovery category is too broad, or is irrelevant
The discovery requested has been received and is presently in the possession or under the control of defendant (plaintiff)
Further discovery would be harassment, time-consuming, expensive, and/or would impose undue hardship on defendant (plaintiff)
Further discovery would unnecessarily delay trial
If it is a discovery relating to medical examination, the grounds could be that it would be injurious to the health and welfare of the client; alternatively, if it is allowed, that it be restricted to one examination.