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.
Tarrant Texas 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 in a court case in Tarrant County, Texas. This motion is typically filed when the party believes that the proposed deposition location stated in the notice is inconvenient, burdensome, or not in the best interest of justice. By filing this motion, the party seeks to request the court to order that the deposition be conducted at a different location that they consider more suitable. The Tarrant Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice can be categorized into several types based on the grounds mentioned in the motion. Some possible types of such motions include: 1. Inconvenience: This type of motion is filed when the proposed deposition location is logistically inconvenient for the party. This could be due to travel distances, accessibility issues, or other practical considerations that make the initially stated location impractical. 2. Burden: This type of motion is filed when the proposed deposition location places an undue burden on the party. This may include factors such as excessive travel expenses, time constraints, or other circumstances that make it difficult for the party to attend the deposition at the originally stated place. 3. Safety or Security Concerns: This type of motion is filed when the party believes that the initially stated deposition location poses a risk to their safety or security. This could involve concerns such as a dangerous or hostile environment, potential threats, or the need for additional protection measures. 4. Confidentiality or Privacy: This type of motion is filed when the party believes that the proposed deposition location lacks the necessary confidentiality or privacy for the nature of the case. The party may argue that a different location will provide a more secure environment to discuss sensitive or confidential information without the risk of unauthorized disclosure. 5. Other Relevant Grounds: There may be additional circumstances or grounds specific to the case that warrant filing a Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice. These grounds could include issues such as the need for specialized facilities, language accessibility considerations, or any other legitimate concerns that may arise during the deposition process. It is important to note that the specific types of motions mentioned above are not exhaustive and that the grounds for filing a motion can vary depending on the unique circumstances of each case. The Tarrant Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice provides an avenue for parties to address any concerns they may have regarding the deposition location, ensuring that the deposition process is fair, efficient, and conducted in a manner that serves the interests of justice.
