Rule 192.6 of the Texas Rules of Civil Procedure states:
(a) Motion. A person from whom discovery is sought, and any other person affected by the discovery request, may move within the time permitted for response to the discovery request for an order protecting that person from the discovery sought. A person should not move for protection when an objection to written discovery or an assertion of privilege is appropriate, but a motion does not waive the objection or assertion of privilege. If a person seeks protection regarding the time or place of discovery, the person must state a reasonable time
and place for discovery with which the person will comply. A person must comply with a request to the extent protection is not sought unless it is unreasonable under the circumstances to do so before obtaining a ruling on the motion.
(b) Order. To protect the movant from undue burden, unnecessary expense, harassment, annoyance, or invasion of personal, constitutional, or property rights, the court may make any order in the interest of justice and may - among other things - order that:
(1) the requested discovery not be sought in whole or in part;
(2) the extent or subject matter of discovery be limited;
(3) the discovery not be undertaken at the time or place specified;
(4) the discovery be undertaken only by such method or upon such terms and conditions or at the time and place directed by the court;
(5) the results of discovery be sealed or otherwise protected, subject to the provisions of Rule 76a.
In Austin, Texas, a Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice is a legal document filed by a party involved in a lawsuit. This motion requests the court's permission to change the location of a deposition from the place originally stated in the notice provided to the opposing party. The purpose of this motion is usually to accommodate the convenience of the parties involved, avoid unnecessary travel expenses or hardships, or facilitate a more efficient legal process. It may also be filed if the initially chosen location becomes impractical or inaccessible due to unforeseen circumstances. When filing a Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice, it is essential to include relevant keywords and information to support the request. These may include the reasons why the change of location is necessary, any financial or logistical burden it would impose on the parties, and any potential benefits to the legal proceedings. Different types of motions that fall under this category could involve changing the deposition location from one city to another based on the convenience of the parties, or requesting a different location within the same city due to factors such as unavailability of the originally chosen facility or the need for specialized equipment or resources. It is crucial to consult with an attorney or review the local rules of court to understand the specific requirements and procedures for filing this motion in Austin, Texas, as they may vary slightly depending on the jurisdiction and the court where the lawsuit is being heard. Moreover, it is important to provide a compelling argument and valid grounds for the change in location to increase the likelihood of the court granting the motion.
