Q: How come Motion for Protective order is valid response to Motion to Compel, given info

A: Under California law, a Motion for a Protective Order can be a valid response to a Motion to Compel discovery for a few reasons:

1. General provision: The California Code of Civil Procedure (CCP) § 2017.020(a) states that the court may, for good cause shown, make any order that justice requires to protect any party or other person from unwarranted annoyance, embarrassment, oppression, or undue burden and expense. This broad provision allows for protective orders in response to discovery requests, including motions to compel.

2. Timing: CCP § 2030.090(a) (for interrogatories) and CCP § 2031.060(a) (for inspection demands) allow a party to move for a protective order before the date on which a response to the discovery is due. This means that a party can file a motion for a protective order in response to a motion to compel, as long as it is filed before the deadline to respond to the original discovery request.

3. Objections: If a party objects to a discovery request and the opposing party files a motion to compel, the objecting party may seek a protective order to justify their objections and protect themselves from the motion to compel. The protective order can address issues such as undue burden, privilege, or the scope of discovery.

4. Court's discretion: Ultimately, the court has broad discretion to manage discovery and issue protective orders as it sees fit to promote justice and prevent abuse of the discovery process, as outlined in CCP § 2017.020(a).

While the specific sections you mentioned (CCP §§ 2031.210, 2031.220, 2031.230, 2031.240, and 2031.280) do not explicitly reference motions for protective orders, the general provisions and the court's discretion allow for protective orders to be used as a response to motions to compel when appropriate.