Section 2.36 Showing Required for Order

LibraryDiscovery 2015


There must be a showing that an order is necessary to protect either a party or third person from whom discovery is sought from annoyance, embarrassment, oppression, or undue burden or expense. The burden is on the person seeking the order, State ex rel. Schott v. Foley, 741 S.W.2d 111 (Mo. App. E.D. 1987), and generally must be supported by fact rather than unsupported contentions or conclusions. See:



· 8A CHARLES A. WRIGHT ET AL., FEDERAL PRACTICE AND PROCEDURE: CIVIL § 2035 ((3rd ed. 2010)



· Gen....

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