Utah Sample Letter for Plaintiff's Motion for Protective Order, Motion to Quash, Objection to Notice of Deposition Ducks Cecum [Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] [Recipient's Name] [Recipient's Position] [Recipient's Address] [City, State, ZIP] Re: Case No. [Case Number] — Plaintiff's Motion for Protective Order, Motion to Quash, Objection to Notice of Deposition Ducks Cecum Dear [Recipient's Name], I hope this letter finds you well. I am writing on behalf of the plaintiff in the aforementioned case, [Plaintiff's Name]. We have recently received a Notice of Deposition Ducks Cecum from your office, requesting the production of certain documents. This correspondence serves as our formal response, which includes a Motion for Protective Order, Motion to Quash, and Objection to the aforementioned notice. 1. Plaintiff's Motion for Protective Order: In light of the circumstances of this case, we believe it is necessary to file a Motion for Protective Order. This motion is intended to protect the plaintiff from any harassment, inconvenience, or unnecessary disclosure of sensitive or privileged information during the deposition or any subsequent proceedings. We respectfully request that the court grants this motion to ensure a fair and just process while balancing the need for discovery. 2. Plaintiff's Motion to Quash: Additionally, we are filing a Motion to Quash the Notice of Deposition Ducks Cecum for several reasons. First, the notice fails to comply with the relevant procedural rules of the court. Second, we contend that the requested documents are irrelevant, overly burdensome, or confidential in nature, which should exempt them from production. Finally, we believe the notice was served improperly, and therefore, fails to meet the necessary requirements for a valid deposition. 3. Plaintiff's Objection to Notice of Deposition Ducks Cecum: Furthermore, we would like to formally object to the Notice of Deposition Ducks Cecum on substantive grounds. We argue that the deposition is an attempt to harass, annoy, or unduly burden the plaintiff. Moreover, the documents requested are either irrelevant to the claims at hand or are protected by the attorney-client privilege, work product doctrine, or other applicable privileges. In conclusion, we request that you consider this detailed response to the Notice of Deposition Ducks Cecum and our accompanying motions. We believe they are essential to protecting the rights and interests of the plaintiff while ensuring a fair and efficient legal process. Please acknowledge receipt of this correspondence and inform us of any necessary further procedures or deadlines regarding these motions. We appreciate your attention to this matter and look forward to a prompt resolution. Thank you for your cooperation. Sincerely, [Your Name]