Cuyahoga Ohio 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
• County: Cuyahoga
• 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. Cuyahoga Ohio Sample Letter for Plaintiff's Motion for Protective Order, Motion to Quash, Objection to Notice of Deposition Ducks Cecum Dear [Recipient's Name], I am writing to bring to your attention a matter of great importance regarding the upcoming deposition in the case of [Plaintiff's Name] versus [Defendant's Name]. As the plaintiff's legal representative, I hereby submit the following motions and objection to ensure the protection of our client's rights and to seek a fair and just legal process. 1. Motion for Protective Order: We kindly request the court's issuance of a protective order to safeguard the confidentiality and privacy of sensitive information that may be disclosed during the deposition. As there are concerns regarding the potential disclosure of trade secrets, privileged information, and personal details, it is crucial that this order be put in place to prevent any potential prejudice or harm to the plaintiff's case or personal interests. 2. Motion to Quash: In accordance with Rule XX of the Ohio Rules of Civil Procedure, we move to quash the notice of deposition duces tecum served upon the plaintiff. The notice seeks to obtain overly broad and unduly burdensome documents and materials that are not reasonably calculated to lead to the discovery of admissible evidence. We assert that this request goes beyond the scope of relevancy, and quashing it would promote a more efficient and focused discovery process. 3. Objection to Notice of Deposition Ducks Cecum: The plaintiff hereby objects to the notice of deposition duces tecum received from the defendant's counsel. We assert that the notice fails to sufficiently describe the materials sought and imposes undue burden and expense on our client. Additionally, the notice fails to state a reasonable time and place for the deposition and asks for the production of documents that are protected by the attorney-client privilege. In support of these motions and objection, we respectfully request an immediate hearing to address these concerns and seek the court's intervention, if necessary. Our client's rights should not be jeopardized by the defendant's overreaching discovery requests or the potential disclosure of privileged or sensitive information. Thank you for your attention to this matter. We look forward to your prompt response and a resolution that upholds the principles of fairness and justice in this case. Sincerely, [Your Name] [Your Law Firm's Name] [Address] [City, State, ZIP] [Phone Number] [Email Address] Optional: cc: [Opposing Counsel's Name]

Cuyahoga Ohio Sample Letter for Plaintiff's Motion for Protective Order, Motion to Quash, Objection to Notice of Deposition Ducks Cecum Dear [Recipient's Name], I am writing to bring to your attention a matter of great importance regarding the upcoming deposition in the case of [Plaintiff's Name] versus [Defendant's Name]. As the plaintiff's legal representative, I hereby submit the following motions and objection to ensure the protection of our client's rights and to seek a fair and just legal process. 1. Motion for Protective Order: We kindly request the court's issuance of a protective order to safeguard the confidentiality and privacy of sensitive information that may be disclosed during the deposition. As there are concerns regarding the potential disclosure of trade secrets, privileged information, and personal details, it is crucial that this order be put in place to prevent any potential prejudice or harm to the plaintiff's case or personal interests. 2. Motion to Quash: In accordance with Rule XX of the Ohio Rules of Civil Procedure, we move to quash the notice of deposition duces tecum served upon the plaintiff. The notice seeks to obtain overly broad and unduly burdensome documents and materials that are not reasonably calculated to lead to the discovery of admissible evidence. We assert that this request goes beyond the scope of relevancy, and quashing it would promote a more efficient and focused discovery process. 3. Objection to Notice of Deposition Ducks Cecum: The plaintiff hereby objects to the notice of deposition duces tecum received from the defendant's counsel. We assert that the notice fails to sufficiently describe the materials sought and imposes undue burden and expense on our client. Additionally, the notice fails to state a reasonable time and place for the deposition and asks for the production of documents that are protected by the attorney-client privilege. In support of these motions and objection, we respectfully request an immediate hearing to address these concerns and seek the court's intervention, if necessary. Our client's rights should not be jeopardized by the defendant's overreaching discovery requests or the potential disclosure of privileged or sensitive information. Thank you for your attention to this matter. We look forward to your prompt response and a resolution that upholds the principles of fairness and justice in this case. Sincerely, [Your Name] [Your Law Firm's Name] [Address] [City, State, ZIP] [Phone Number] [Email Address] Optional: cc: [Opposing Counsel's Name]