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.
Carrollton, Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice allows individuals involved in a legal proceeding to request a change in the location where a deposition is to take place. This motion is typically filed when the originally designated place for the deposition is inconvenient, impractical, or poses logistical challenges for one or both parties involved. There are different types of Carrollton Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice, which can include: 1. Motion to Change Deposition Location: This type of motion is filed when there is a need to move the deposition to a different place due to various reasons such as distance, accessibility, or security concerns. 2. Motion for Deposition to be taken at the Office of Attorney: This motion is filed when one party requests that the deposition be conducted at their attorney's office instead of the initially scheduled location. It is often done for the convenience of the deponent or to ensure a more conducive environment for the questioning. 3. Motion for Deposition to be taken at a Neutral Location: Sometimes, in cases where the parties involved may have conflicts or disputes with certain venues, a neutral location is sought for the deposition to ensure fairness and impartiality. This motion requests that the deposition take place at a mutually agreed-upon neutral location, such as a conference center or a deposition facility. 4. Motion for Deposition to be taken via Videoconference: With the advancement of technology, videoconferencing has become a popular option for conducting depositions remotely. This motion requests that the deposition be taken via videoconference at a designated place, such as a legal videoconferencing facility, to save travel time and expenses. By filing a Carrollton Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice, parties involved in a legal proceeding can ensure that the deposition process is conducted in a manner that is fair, efficient, and convenient for all parties involved, taking into consideration the logistics and circumstances of the original deposition notice.
