Motion for Protective Order

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01ATTORNEY INFORMATION

Attorney Name *

State Bar No. *

Firm / Office Name

Address *

Phone *

Fax

Email *

02CASE INFORMATION

County *

File No. *

Division

Moving Party *

Moving Party is

Opposing Party *

03DISCOVERY AT ISSUE

Type of Discovery *

Discovery Description *

04GROUNDS FOR PROTECTION

Select All Applicable Grounds *

Other Ground — Description

Facts Supporting Grounds *

05PROPOSED PROTECTIVE ORDER TERMS

Select All Applicable Terms

Other Term — Description

Cases Cited

06GOOD-FAITH CONFERENCE CERTIFICATION

Date of Conference *

Conferenced With *

Outcome *

Service Date *

Served Upon *

SELECTED COUNTY

— Select above —

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RULE 26(c) CHECKLIST

File before or promptly after discovery is served on your client
Court weighs burden on producing party vs. need of requesting party
For trade secrets: show specific harm if disclosed, not just general confidentiality
For medical/mental health records: HIPAA and NC privacy law apply — cite both
Proposed order with specific terms is more likely to be granted than a general request
Clerk can enter a protective order in some cases — attach a proposed form of order

STATUTORY REFERENCE

G.S. 1A-1, Rule 26(c)Protective orders

Rule 26(b)(3)Work product protection

G.S. 132-1.2Trade secrets

HIPAA §164.512(e)Medical records / litigation

G.S. 8-53Physician-patient privilege

NEED AN ATTORNEY?

This motion requires a licensed NC attorney to sign and file
Barker Richardson, PLLC → for civil litigation

Motion for Protective Order (Discovery)

AUTO-FILL FROM CLIO

RULE 26(c) CHECKLIST

STATUTORY REFERENCE

NEED AN ATTORNEY?