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 Duces Tecum
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FAQ
After the motion to quash is filed, the court will review the case and make its determination. For example, if the judge grants a motion to quash service, then the service on the defendant would be considered void. A motion to quash that is approved would also invalidate any applicable decisions from a lower court.
Objecting to Notice of Deposition Specifically, section 2025.410 states that the party served with the defective notice of deposition waives the defect unless that party serves a written objection at least three (3) calendar days prior to the date the deposition is scheduled.
A motion to quash is a request to a court or other tribunal to render a previous decision or proceeding null or invalid. The exact usage of motions to quash depend on the rules of the particular court or tribunal. In some cases, motions to quash are requests to nullify a decision made by the same or a lower court.
A quash definition would be to reject, or void, especially by a legal procedure. Simply put, it is a verb meaning to put an end to. A motion to quash refers to a specific type of request, in which one court is asked to render the decision made by another, lower court as invalid.
Motions to quash shall be filed with the board and served upon the opposing party prior to a hearing. Unless a motion to quash has been granted, a witness shall attend the hearing to which he or she was subpoenaed subject to the provisions contained within paragraph (C) of this rule.
Objecting to Notice of Deposition Specifically, section 2025.410 states that the party served with the defective notice of deposition waives the defect unless that party serves a written objection at least three (3) calendar days prior to the date the deposition is scheduled.
To set aside; to void. As in "to quash a motion" or "quash evidence."
In most types of cases, for the deposition of a party to the case, you must provide at least 10 days' notice if personally served, and 15 days' notice if served by mail within California (California Code of Civil Procedure (CCP) § 2025.270(a), § 1013).
A motion to quash is timely if made before the date specified in the subpoena for compliance. In considering a motion to quash, the trial court may hold a hearing and, as necessary, entertain any relevant testimony.
Usually, the filing of a motion to quash means you can refuse to comply with the subpoena until the court either denies the motion, or you reach an agreement with the party that served you with the subpoena.
