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.
Bexar Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice refers to a legal document filed by a party in a lawsuit requesting the court's permission to change the location of a scheduled deposition. This motion is commonly used in civil litigation cases when unforeseen circumstances arise or when parties find it more convenient or advantageous to conduct the deposition at a different location than originally specified in the notice. The Bexar Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice allows the party seeking the change to present valid justifications to convince the court to grant the requested modification. Some common reasons for requesting a change in deposition location include the unavailability of witnesses or experts at the original location, the need for specialized equipment or facilities, or the convenience and cost-effectiveness of an alternative venue. Types of Bexar Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice may include: 1. Emergency Motion for Change of Deposition Location: This motion is filed when unexpected events or urgent circumstances require an immediate change in the deposition venue. For example, if a witness or attorney falls ill or encounters travel issues, an emergency motion may be filed to reschedule the deposition at a more accessible or suitable location. 2. Motion for Change of Deposition Location due to Witness or Expert Availability: This type of motion is utilized when a crucial witness or expert is unable to attend the deposition at the originally designated location. The party may request a change to a location where the witness or expert is available or more convenient for their participation. 3. Motion for Change of Deposition Location based on Specialized Equipment or Facilities: In cases where the use of specialized equipment or facilities is necessary for the deposition, a party may file this motion to change the location to a venue equipped with the required resources. For instance, if a deposition requires high-tech audiovisual equipment, the motion may propose relocating to a facility that can fulfill these needs. 4. Motion for Change of Deposition Location for Convenience or Cost factors: Parties involved in a lawsuit may find it more convenient or cost-effective to conduct the deposition at a different location. This motion is filed to persuade the court that moving the deposition will be more beneficial for the parties or their legal representatives, potentially saving travel costs, time, or effort associated with attending the deposition originally scheduled. In conclusion, the Bexar Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice is a legal tool used to request a change in the location of a deposition. The types of motions within this category can vary, depending on the specific circumstances prompting the request. Legal parties must provide clear justifications to persuade the court to grant the desired change.
