Subject: Request for Protective Order for Documents in New York State Dear [Recipient's Name], I hope this letter finds you well. I am writing to request a protective order regarding certain documents that are currently in possession or control of [Name of Opposing Party or Entity]. The purpose of this protective order is to ensure the confidentiality and non-disclosure of sensitive information during the discovery process in the [Case Name or Docket Number] pending in the [Name of Court] in New York State. In accordance with the New York Civil Practice Law and Rules (CPR), particularly Section 3103(a), I believe it is necessary to establish a protective order to safeguard the confidential information contained within the documents produced by either party involved in this case. The feared harm resulting from the indiscriminate dissemination of such information outweighs the mere inconvenience that may arise from implementing this protective measure. [Optional: Specify the nature of the protective order being sought here, such as "attorney's eyes only" or "confidential — outside counsel only"] To support my request, I have included a description of the documents subject to this protective order. The following documents are likely to contain sensitive information that should be protected: 1. [Include a detailed description of the first set of documents] 2. [Include a detailed description of the second set of documents] 3. [Include a detailed description of any additional sets of documents] I firmly believe that without the confidentiality and protection provided by this proposed protective order, there is a significant risk of harm to the parties involved, breach of privacy, or potential misuse of sensitive information. Therefore, I kindly request an expedited review and approval of this protective order to prevent any potential damage or unauthorized disclosure. This protective order shall remain in effect until further ordered by the court or by mutual consent of the parties involved. I am open to discussing any modifications or additional requirements that you may propose for the protective order's terms. Thank you for your attention to this matter. Please find enclosed a copy of the proposed protective order for your review. I kindly request your prompt action and issuance of the appropriate protective order at the earliest possible time. Should you have any questions or require any additional information, please do not hesitate to contact me directly at [Your Contact Information]. I look forward to your positive response. Yours sincerely, [Your Name] [Your Title/Position] [Your Organization/Company] [Your Contact Information]