§ 2030.090.Motion for protective order; types of protective orders;

Once interrogatories have gone out, the responding party, or another party or affected natural person or organization, is not stuck answering everything as written. This section gives that party a protective-order motion, but only after first attempting to work things out informally, the motion must be accompanied by a meet-and-confer declaration confirming a genuine attempt at resolution before running to court.

If good cause is shown, the range of relief a court can order is broad and expressly non-exclusive. It can excuse an entire set, or particular interrogatories, from needing an answer at all; it can find that the number of specially prepared interrogatories claimed to be justified under Section 2030.040 is not warranted after all; it can extend the response deadline set by Section 2030.260; it can impose specified terms and conditions on the response; it can direct that a deposition replace interrogatories as the discovery method for a given subject; or it can seal some or all of the answers pending further court order, useful where trade secrets or other confidential business information are involved. If the court denies the motion in whole or in part, it can still condition the discovery that goes forward on terms that are just to the responding party. And whichever side loses the motion faces a mandatory monetary sanction under Chapter 7, unless the court finds substantial justification for that side's position or finds the sanction would otherwise be unjust, a rule that discourages both abusive interrogatories and meritless protective-order motions alike.