Idaho Sample Letter for Plaintiff's Motion for Protective Order, Motion to Quash, Objection to Notice of Deposition Duces Tecum

• Category: Letters - Legal - Documents
• State: Multi-State
• Control #: US-0892LTR
• Format: Word; Rich Text

Description

This form is a sample letter in Word format covering the subject matter of the title of the form. Idaho Sample Letter for Plaintiff's Motion for Protective Order, Motion to Quash, Objection to Notice of Deposition Ducks Cecum [Your Name] [Your Address] [City, State, ZIP] [Date] [Recipient's Name] [Recipient's Address] [City, State, ZIP] Subject: Plaintiff's Motion for Protective Order, Motion to Quash, and Objection to Notice of Deposition Ducks Cecum Dear [Recipient's Name], I hope this letter finds you well. I am writing as the plaintiff in the aforementioned case, [Case Name]. I would like to formally request a protective order, motion to quash, and object to the notice of deposition duces tecum served upon me by the defendant. 1. Plaintiff's Motion for Protective Order: A protective order is necessary to safeguard the confidentiality of privileged information, maintain the integrity of attorney-client privilege, and protect sensitive personal details from unnecessary disclosure. In accordance with the Idaho Rules of Civil Procedure [Insert relevant rule number], I request the court to issue a protective order to prevent the unauthorized dissemination or use of any documents, information, or evidence obtained during the discovery process. 2. Motion to Quash: I hereby move to quash the notice of deposition duces tecum for the following reasons: a. Lack of Proper Notice: The notice fails to comply with the Idaho Rules of Civil Procedure in terms of form and timing requirements. Specifically, it was served [days, hours, etc.] less than the minimum notice period required by Rule [Insert relevant rule number]. b. Unreasonable Burden: The notice imposes an excessive burden on the plaintiff, as it demands the production of documents and materials that are either irrelevant, privileged, or protected by other legal rights. c. Over broad and Unduly Burdensome: The scope of the requested deposition duces tecum is unreasonably broad and conflicts with the proportionality principle stipulated in Rule [Insert relevant rule number]. This motion seeks to narrow the request to only those documents and materials directly relevant to the subject of the lawsuit. 3. Objection to Notice of Deposition Ducks Cecum: In addition to the motion to quash, I object to the notice of deposition duces tecum on the following grounds: a. Privilege and Work Product: The defendant seeks to obtain information protected by privilege or work product immunity. These documents and materials are shielded from discovery, and their production would violate my rights under the law. b. Relevancy and Proportionality: The requested documents and materials are not directly relevant to the issues in this case, nor are they proportional to the needs of the lawsuit, as stipulated in the Idaho Rules of Civil Procedure. Please consider this letter as a formal request for the court's intervention and ruling in support of the motion for protective order, motion to quash, and objection to the notice of deposition duces tecum herein. Thank you for your prompt attention to this matter. I look forward to receiving confirmation of the court's decision. Sincerely, [Your Name] [Your Phone Number] [Your Email Address]

Idaho Sample Letter for Plaintiff's Motion for Protective Order, Motion to Quash, Objection to Notice of Deposition Ducks Cecum [Your Name] [Your Address] [City, State, ZIP] [Date] [Recipient's Name] [Recipient's Address] [City, State, ZIP] Subject: Plaintiff's Motion for Protective Order, Motion to Quash, and Objection to Notice of Deposition Ducks Cecum Dear [Recipient's Name], I hope this letter finds you well. I am writing as the plaintiff in the aforementioned case, [Case Name]. I would like to formally request a protective order, motion to quash, and object to the notice of deposition duces tecum served upon me by the defendant. 1. Plaintiff's Motion for Protective Order: A protective order is necessary to safeguard the confidentiality of privileged information, maintain the integrity of attorney-client privilege, and protect sensitive personal details from unnecessary disclosure. In accordance with the Idaho Rules of Civil Procedure [Insert relevant rule number], I request the court to issue a protective order to prevent the unauthorized dissemination or use of any documents, information, or evidence obtained during the discovery process. 2. Motion to Quash: I hereby move to quash the notice of deposition duces tecum for the following reasons: a. Lack of Proper Notice: The notice fails to comply with the Idaho Rules of Civil Procedure in terms of form and timing requirements. Specifically, it was served [days, hours, etc.] less than the minimum notice period required by Rule [Insert relevant rule number]. b. Unreasonable Burden: The notice imposes an excessive burden on the plaintiff, as it demands the production of documents and materials that are either irrelevant, privileged, or protected by other legal rights. c. Over broad and Unduly Burdensome: The scope of the requested deposition duces tecum is unreasonably broad and conflicts with the proportionality principle stipulated in Rule [Insert relevant rule number]. This motion seeks to narrow the request to only those documents and materials directly relevant to the subject of the lawsuit. 3. Objection to Notice of Deposition Ducks Cecum: In addition to the motion to quash, I object to the notice of deposition duces tecum on the following grounds: a. Privilege and Work Product: The defendant seeks to obtain information protected by privilege or work product immunity. These documents and materials are shielded from discovery, and their production would violate my rights under the law. b. Relevancy and Proportionality: The requested documents and materials are not directly relevant to the issues in this case, nor are they proportional to the needs of the lawsuit, as stipulated in the Idaho Rules of Civil Procedure. Please consider this letter as a formal request for the court's intervention and ruling in support of the motion for protective order, motion to quash, and objection to the notice of deposition duces tecum herein. Thank you for your prompt attention to this matter. I look forward to receiving confirmation of the court's decision. Sincerely, [Your Name] [Your Phone Number] [Your Email Address]