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.
Beaumont Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice refers to a legal procedure that allows a party in a lawsuit in Beaumont, Texas, to request a change in the location of a scheduled deposition. When a deposition is initially noticed, it typically includes a specific location where the deposition will take place. However, circumstances may arise where a party may need to relocate the deposition to a different designated place. In such cases, the party seeking the change can file a motion with the court to request the order. The motion should provide a detailed explanation of why the change is necessary, ensuring to include relevant keywords to address the specific circumstances. The court will then review the motion and determine whether to grant the order, depending on the merits of the arguments presented. There are several types of Beaumont Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice, including: 1. Emergency Motion for Change of Deposition Location: This type of motion is filed when there is an urgent need to relocate the deposition due to unforeseen circumstances, such as natural disasters, medical emergencies, or other sudden events that make the original location inaccessible or unsafe. 2. Motion for Change of Deposition Location based on Convenience: This type of motion is filed when one party or their attorney seeks to change the deposition location for the convenience of themselves, their client, or witnesses involved in the case. Examples of situations where this motion may be appropriate to include witness availability, travel constraints, or logistical considerations. 3. Motion for Change of Deposition Location due to Unreasonable Burden or Expense: This motion is filed when a party believes that the original deposition location stated in the notice would impose an excessive burden or incur substantial expenses. The party must provide evidence and arguments to demonstrate why the change in location would be reasonable and less burdensome. It is important to consult with an attorney experienced in Texas civil procedure and Beaumont jurisdiction to determine the appropriate type of motion and to ensure compliance with the relevant rules and regulations.
