Motion and Memorandum in Support of Motion to Compel Discovery – Pornography

Legal arguments on arguing a protective order limiting reenactment or demonstrative presentation at a deposition. The legal argument that good cause exist to limit an attorney use of video or pictures for reenactment or to demonstrate at a deposition is included in this document. Guidelines set forth in the United States supreme court case Emerson Elec. Co, which includes protection for unwarranted annoyance and embarrassment is included. Protection Order argument is for civil cases.