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.
A Brownsville 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. This motion can be used in various situations where the initially proposed location is inconvenient, burdensome, or unfair to the party requesting the change. By filing this motion, the party seeks to ensure a fair and reasonable deposition process. There are several types of motions related to changing the deposition location in Brownsville, Texas. These may include: 1. Motion to Change Deposition Location: This type of motion requests a change in the location of the deposition, providing valid reasons for the change. The party may argue that the initially proposed location is too far from their office or their client's residence, causing significant inconvenience and travel expenses. 2. Motion to Depose at a Designated Place: In some cases, the party may propose a specific location where they believe the deposition should take place. This motion argues that the proposed location is more appropriate and convenient for all parties involved. The proposed location may be closer to the relevant witnesses, evidence, or experts, ensuring a more efficient and fair deposition process. 3. Motion to Compel Deposition at a Designated Place: If one party has repeatedly refused to agree to a reasonable alternative location for the deposition, the opposing party may file a motion to compel. This motion asserts that the initially proposed location is unfair, unjust, or unduly burdensome to one of the parties, and requests the court to order a change in the deposition location. Filing a Brownsville Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice requires thorough preparation and supporting arguments. The party must demonstrate that the proposed change in location is reasonable and necessary for the smooth progression of the case. It is essential to provide valid reasons, such as the inconvenience or travel expenses associated with the initially proposed location, or any other factors that may hinder the fair conduct of the deposition. Overall, a Brownsville Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice allows parties to seek a change in the deposition location, ensuring a fair and efficient process for all parties involved.
