A motion for protective order asks a court to limit, restrict, or shield the scope, method, or disclosure terms of discovery — whether that means blocking an overbroad document request, protecting sensitive commercial information, limiting the location or duration of a deposition, or restricting who can see produced material. Courts do not grant these routinely; nearly every jurisdiction requires a showing of good cause, and a motion that just asserts the discovery is burdensome or sensitive without evidence tends to fail.

The strongest motions treat the good-cause standard as a factual burden to be proven, not a phrase to be recited. That means building a specific, evidence-backed record of the actual harm the discovery would cause, and — in most jurisdictions — showing the parties genuinely tried and failed to resolve the dispute before bringing it to the court.

Most jurisdictions and federal rules require a genuine, good-faith attempt to resolve the discovery dispute before filing — not a single email demand followed immediately by a motion. Document the actual conferral: dates, participants, positions exchanged, and why agreement wasn't reached. A motion that skips or shortcuts this step is often denied on that basis alone, regardless of the merits.

Good cause requires more than the discovery being inconvenient or unwelcome — courts generally require a specific showing of harm: competitive injury from disclosing trade secrets, undue burden measured in real cost or time, harassment, or annoyance disproportionate to any legitimate discovery need. Generic assertions of burden or sensitivity, without supporting facts, are the most common reason these motions fail.

Courts are far more receptive to a motion that proposes a proportionate middle ground — a confidentiality designation, an attorneys'-eyes-only tier, a narrower scope or time period, a cost-shifting arrangement — than one that simply asks to block discovery outright. Come to the motion with the protective order's actual proposed terms attached, not just an argument that some protection is warranted.

Attach declarations, cost estimates, or documentation supporting the claimed harm — a burden claim is far stronger with an affidavit estimating actual hours and cost than with an assertion in the brief alone. Where trade secret or competitive harm is claimed, be specific about what makes the information sensitive and why disclosure — even under a confidentiality order — would cause real injury.

Expect the opposing party to argue the discovery is relevant, proportional, and that any burden is outweighed by the case's needs. Address the proportionality factors — the amount in controversy, the parties' resources, the importance of the discovery to the case — directly in the motion rather than leaving them for reply, since many courts weigh proportionality as part of the good-cause analysis itself.