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Chapter 5

Form 5-7

Include the following notice if a minor is named in the caption or if the motion contains other unredacted sensitive data. See § 6 of the Introduction in volume 1 of this manual concerning protection of sensitive data in filed documents.

NOTICE: THIS DOCUMENT
CONTAINS SENSITIVE DATA

[Caption. See § 3 of the Introduction in volume 1 of this manual.]

Motion for Confidentiality Order

This Motion for Confidentiality Order is brought by [name of movant], [party designa­tion], who shows in support:

1.[Name of movant] has been served with a discovery request requiring [him/her] to produce certain designated records. A copy of the discovery document is attached.

2.[Name of movant] seeks a confidentiality order to prevent disclosure of sensitive personal, financial, and business information to third parties, the disclosure of which could cause injury to the producing party.

[Name of movant] prays that the Court grant a confidentiality order.

   
[Name]
Attorney for [name of movant]
State Bar No.:
[Email address]
[Address]
[Telephone]
[Fax]

Certificate of Conference

I certify that a reasonable effort has been made to resolve the discovery dispute without the necessity of court intervention and has failed.

   
[Name]
Attorney for [name of movant]

For certificate of service, see form 21-11.