Asks the court to shield a party from abusive or unduly burdensome discovery. Common in cases involving trade secrets, medical records, or third-party subpoenas.
A request asking the court to limit, prohibit, or condition discovery to protect a party or non-party from annoyance, embarrassment, oppression, or undue burden. Often used to seal trade secrets, restrict deposition topics, or stop third-party subpoenas.
Filed when a party receives a discovery request or subpoena that exposes confidential information, harasses, or imposes disproportionate burden. Frequently paired with a request for a confidentiality order governing how produced documents may be used.
Opposes by arguing the information is relevant and not privileged, the burden is reasonable given the case stakes, or that less-restrictive alternatives (redaction, AEO designation) suffice.
Granted (order issued limiting discovery), denied (full discovery proceeds), or modified (court enters its own version of a protective order — common in trade-secret cases).