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obtaining an order from the court they can exceed that limit.
Also, a party can file a protective order blocking or limiting
the requests, or limiting the information requested.

Motion to Stay Discovery and Trial
Concurrent with filing the answer to the complaint, Fields'
office also filed a Motion for Stay of Discovery and Trial until
the statute of limitations expired on the criminal investigation
involving the same charges. The statute of limitations for this
type of case is six years. A motion is a vehicle by which you
can address the court within a short period of time (generally
14 to 28 days) to get an order on a particular issue. The motion
was set for a hearing on November 19, 1993 at 1:30 P.M..
In Mr. Fields' Memorandum of Points and Authorities (this
is the section of the motion that states the law as it applies to
this case, or as it was applied in similar cases before), he al-
leged that, "the allegations arose solely out of an attempt by
Dr. Chandler, the little boy's father, and his father's attorney,
Barry Rothman, to extort twenty million dollars from Michael
Jackson." He further stated that, "when the defendant refused
to pay blackmail money, Dr. Chandler induced his son to make
the false allegations of sexual abuse against Michael Jackson."
Mr. Fields' stated reason for filing the Motion to Stay Dis-
covery and Trial was on the grounds that when a civil defen-
dant faces possibility of criminal prosecution for the same fac-
tual allegations as alleged in the civil action, according to Fed-
eral and California law, the defendant is entitled to Stay the
Discovery and Trial in civil proceedings until the statute of
limitation has expired on the criminal case. The law that Mr.
Fields cited was, Pacers, Inc. v. Superior Court, 162 Cal.App.3d
686, 208 Cal.Rptr. 743 (1984).

Excerpts from Pacers Inc. v. Superior Court reads as fol-
lows:
"An order to Stay Discovery until expiration would allow
plaintiffs to prepare their lawsuit while alleviating civil defen-

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