MOVING PARTY: Defendant LA County MTA
Motion for Protective Order

The court considered the moving papers.
On May 31, 2017, plaintiff Genoveva Galvez filed a complaint against defendant LA County MTA for motor vehicle negligence based on an incident that occurred on January 17, 2017.
On November 15, 2017, plaintiff filed a First Amended Complaint.
Trial is set for November 30, 2018.
Protective orders may be granted on motion of the deponent or any party, or any third person who could be affected by the disclosure (e.g., a nonparty whose privacy would be
impaired). CCP §2025.420(a). A formal noticed motion and hearing are always required. A protective order cannot be granted ex parte. St. Paul Fire & Marine Ins. Co. v. Superior Court (1984) 156 Cal. App. 3d 82, 85-86. The motion must be accompanied by a declaration stating facts showing a “reasonable ........