[CLBS] (Out of state) Motion for Protective Order to preempt further harassment - samples?

[Holly Roark]

Does anyone have a sample federal Motion for Protective Order (adversary
case) that they could share with me? This has to do with my client being
harassed in a deposition by the pro se debtor/defendant ex-husband who
Noticed the Depo. We actually terminated the depo because of it and he is
going to file a motion to compel. 

 

I have filed for protective orders before, but only with respect to specific
documents. Here, I want to file something a little different, if that's
possible, where we can preempt further harassment of my client. She has a
domestic violence order from family court -it's valid for 101 (that's one
hundred one) years, and it was clear that the depo raised issues not
relevant to our adversary case and was designed to harass, confuse, etc. 

 

I want to preempt the Motion to Compel with a motion for protective order
against further harassment, or at the very least to put in a discovery
referee who can weed out the harassing and irrelevant questions. Any ideas
or samples? 

 

Best regards,

HOLLY ROARK

Attorney at Law 

Certified Bankruptcy Specialist -

By the State Bar of California Board of Legal Specialization

 

ROARK LAW OFFICES

950 Bannock Street | 11th Floor | Boise, Idaho 83702

Phone:  (208) 536-3638 (Texting is great! Regular business hours only,
please.)

Fax: (310) 553-2601

E-mail:   <mailto:holly at roarklawboise.com> holly at roarklawboise.com 

 

*This communication does not create an attorney-client relationship.

Unless you have signed a retainer agreement with Roark Law Offices, this 

communication may not be private or privileged.