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Parties wishing to keep confidential documents obtained or disclosed during discovery, including for attorneys' eyes only, may file a motion for protective order, with a proposed order, showing good cause for the relief requested.
A motion must include ? in a single document no longer than twenty-five pages inclusive of all parts ? a concise statement of the precise relief requested, a statement of the basis for the request, and a legal memorandum supporting the request.
A motion for protective order is a request made by one party to the court to protect them from potentially harmful actions by the other party, usually in regards to sharing information during the legal process. This can happen when one party wants to access the other party's trade secrets.
A motion for protective order does not automatically stay the deposition and the deposition shall proceed unless an order granting the motion is entered by the Court.