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Protective Order Motion Response
Summary
Incorrect names on a motion can affect its validity. File a response pointing out errors, request dismissal or correction, and attend hearings to argue your case.Full Conversation
RESPONDENT’S MOTION FOR PROTECTIVE ORDER
Respondent, Movant herein, files this Motion for Protective Order and in support
thereof would show the Court the following:
*. This Motion is filed under the provisions of Rules *.* and *.*, Texas Rules
of Civil Procedure.
*. On January *, *, Respondent propounded unto Petitioner the attached
discovery.
*. Trial for this case is set on March *, *. Under TRCP Rule *.*(b), all
discovery must be completed 30 days before the trial date. Therefore, calculating under
TRCP Rule *, discovery would need to be completed by February *, *, i.e. 30 days
before March *, *.
*. Given that the discovery requests were sent on January *, *, the due date
for said discovery is February *, *. This goes past the discovery deadline making
the discovery requests improper and untimely.
*. Movant therefore asks the Court to enter a protective order against Plaintiff’s
discovery requests.
Prayer
Movant prays the Court set this Motion for hearing and, at the conclusion
thereof, the Court enter a protective order as requested above. Movant additionally
prays for such other and further relief to which the Court determines Movant to be
entitled both in equity and at law.
Respectfully submitted,
Page * of *
ILIONSKY LAW, PLLC
* Round Rock West Drive
Suite *
Round Rock, TX *
By: /s/ E. Z. Ilionsky
E. Z. Ilionsky
Attorney for R
Texas Bar No. *
Telephone: (*) *-*
ez@ilionsky.com
Certificate of Service
I certify that a true copy of this document was served in accordance with Rule
21a of the Texas Rules of Civil Procedure on all required parties on January *, *.
By: /s/ E. Z. Ilionsky
E. Z. Ilionsky
Hi **** ****,
It seems like you are dealing with a Motion for Protective Order in Texas. Here are some key points from the Texas Rules of Civil Procedure regarding such motions:
- **Rule *.***: Limits discovery if it is overly burdensome or unnecessary.
- **Rule *.***: Allows for a protective order to protect parties from undue burden or expense.
Is there a specific question you have about this motion or the process involved?
It seems like you are dealing with a Motion for Protective Order in Texas. Here are some key points from the Texas Rules of Civil Procedure regarding such motions:
- **Rule *.***: Limits discovery if it is overly burdensome or unnecessary.
- **Rule *.***: Allows for a protective order to protect parties from undue burden or expense.
Is there a specific question you have about this motion or the process involved?
how do i respond so that i can get my request answered
Hi **** ****,
To ensure your request for a protective order is properly addressed, you can:
- File a written response to the motion, clearly stating why the discovery requests are untimely and burdensome.
- Request a hearing date for the motion to present your arguments in court.
- Ensure all supporting documents are attached and referenced.
Is there a specific part of the process you need more information on?
To ensure your request for a protective order is properly addressed, you can:
- File a written response to the motion, clearly stating why the discovery requests are untimely and burdensome.
- Request a hearing date for the motion to present your arguments in court.
- Ensure all supporting documents are attached and referenced.
Is there a specific part of the process you need more information on?
the names are incorrect on this motion does that mean anything?
Hi **** ****,
Incorrect names on a motion can impact its validity. Here are some steps to consider:
- File a motion to correct the names or request the court to do so.
- Ensure the corrected motion is properly served to all parties involved.
Would you like more detailed guidance on correcting this error?
Incorrect names on a motion can impact its validity. Here are some steps to consider:
- File a motion to correct the names or request the court to do so.
- Ensure the corrected motion is properly served to all parties involved.
Would you like more detailed guidance on correcting this error?
i didn't file the motion it was sent to me
Hi **** ****,
If you received the motion and the names are incorrect, you can take the following steps:
- File a written response pointing out the incorrect names.
- Request the court to dismiss or correct the motion due to the error.
- Attend any scheduled hearings to argue your case.
Would you like more information on how to file a response?
If you received the motion and the names are incorrect, you can take the following steps:
- File a written response pointing out the incorrect names.
- Request the court to dismiss or correct the motion due to the error.
- Attend any scheduled hearings to argue your case.
Would you like more information on how to file a response?
what should my written response say?
Hi **** ****,
In your written response to the motion, you can include the following points:
- **Introduction**: Clearly state your name, your role in the case, and the purpose of your response.
- **Incorrect Names**: Point out the incorrect names and how they affect the motion's validity.
- **Request**: Ask the court to dismiss the motion or require the correction of the names before proceeding.
- **Conclusion**: Restate your request and ask for any additional relief the court deems appropriate.
Would you like a sample template for your response?
In your written response to the motion, you can include the following points:
- **Introduction**: Clearly state your name, your role in the case, and the purpose of your response.
- **Incorrect Names**: Point out the incorrect names and how they affect the motion's validity.
- **Request**: Ask the court to dismiss the motion or require the correction of the names before proceeding.
- **Conclusion**: Restate your request and ask for any additional relief the court deems appropriate.
Would you like a sample template for your response?
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