The plaintiff in the above-entitled action moves this court for a protective order under CPLR 3103 to prevent unreasonable annoyance, embarrassment and/or disadvantage to the plaintiff in the conduct of an examination of the plaintiff upon oral questions, and further for a protective order pursuant to CPLR 3122 and CPLR 3103 limiting the use of a disclosure device as to certain documents requested by the examining defendant.
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