A motion for a protective order asks the court to limit or restrict discovery that's unduly burdensome, invasive of privacy, or seeks to protect trade secrets and other sensitive information from broad disclosure.
Show specific harm, not general reluctance
Courts want to see concrete harm — competitive damage from disclosing trade secrets, genuine burden measured in time and cost, real privacy exposure — rather than a general preference not to produce something.
Propose an alternative, not just a refusal
Motions that offer a narrower scope, a confidentiality designation, or an attorneys'-eyes-only limitation are more persuasive than ones that simply ask to block the request outright.
The meet-and-confer requirement applies here too
Like a motion to compel, most jurisdictions expect a documented good-faith effort to resolve the dispute before the motion is filed — courts are unreceptive to protective order requests that skip straight to litigation.
A stipulated protective order is often faster
In cases involving sensitive business information, negotiating an agreed protective order with the other side — rather than litigating one — is frequently quicker and gets both sides workable terms without a motion at all.