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.
Arlington Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice is a legal action undertaken by one party in a legal case to request a change in the location of a deposition. This motion is typically made when the current location of the deposition, as stated in the notice, is inconvenient, inappropriate, or presents challenges that hinder the fair proceedings of the deposition. Keywords: Arlington Texas, Motion for Order, Deposition, Designated Place, Notice. There are a few types of Arlington Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice: 1. Motion for a Change of Venue: This type of motion is filed when the current location of the deposition is geographically distant or burdensome for one or both parties involved. The moving party requests a change of venue to a more convenient location, typically within Arlington, Texas, to ensure fairness and accessibility. 2. Motion for a Neutral or Impartial Location: If the current location of the deposition is perceived as favoring one party or is associated with bias or inconvenience, one party may file a motion requesting a neutral or impartial location for the deposition. This ensures fair proceedings by eliminating any potential bias associated with the original location. 3. Motion for Safety Concerns: In certain cases, when conducting a deposition at the initially specified location poses a risk to the safety of one or both parties involved, a motion for a change in deposition location can be filed. Safety concerns may arise due to factors such as criminal activity, harassment, or threats. The moving party seeks to relocate the deposition to a secure and protected site, ensuring the well-being of all parties involved. 4. Motion for Confidentiality: If the initial deposition location lacks the necessary privacy or confidentiality required for discussions or sensitive topics, one party may file a motion requesting a new location that respects the confidentiality concerns. The moving party aims to ensure that any sensitive information discussed during the deposition remains protected and undisclosed. 5. Motion for Accessibility: When the current location of the deposition poses accessibility issues for one or both parties, such as physical disabilities or transportation challenges, a motion for a change of the deposition location can be filed. The moving party seeks a more accessible venue that meets the specific needs of all parties involved. In conclusion, an Arlington Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice allows a party to request a change in the location of a deposition when the current location poses difficulties or hinders fairness in legal proceedings. This motion can be categorized into different types, including a change of venue, neutral location, safety concerns, confidentiality, and accessibility.
