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.
In College Station, Texas, a Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice is a legal procedure through which a party requests the court to allow a deposition to be conducted at a location other than the one initially designated in the notice. This motion is often used when unforeseen circumstances arise, such as the unavailability of a specific venue or the convenience of the parties involved. Key factors to consider when drafting a College Station Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice include: 1. Notice — The motion should state the original notice of deposition, including the date, time, and location stated in the notice. 2. Reasoning — Provide a clear and compelling reason for the change in the designated place. This could include unforeseen scheduling conflicts, witness unavailability, or logistical issues. 3. New Designated Place — Clearly identify the proposed new location for the deposition. Ensure it is a suitable and convenient alternative to the original place mentioned in the notice. 4. Timeliness — The motion should be filed promptly after discovering the need for a change in the designated place. Delaying the filing may impact the court's decision, especially if it causes inconvenience or prejudice to the opposing party. 5. Supporting Evidence — Include any supporting evidence, such as witness affidavits, documentation of scheduling conflicts, or other relevant materials that justify the need for the change. Types of College Station Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice may include: 1. Motion for Order to Change Venue — When a party requests a change in the deposition location due to the transfer of the case to a different jurisdiction. 2. Motion for Order due to Witness Unavailability — This motion is filed when a key witness becomes unavailable or is unable to attend the deposition at the originally designated place. The party seeks permission to take the deposition at a different location where the witness is more accessible. 3. Motion for Order based on Scheduling Conflicts — When unexpected scheduling conflicts arise that prevent one or more parties from attending the deposition at the initially designated place, this motion is filed to propose a new location. 4. Motion for Order due to Logistical Issues — If unforeseen logistical issues, such as venue unavailability or inadequate facilities, arise after the notice of deposition has been served, this motion is filed to request a new location that can accommodate the needs of all parties involved. It is essential to consult with an attorney who specializes in Texas civil procedure to ensure the proper drafting and filing of a College Station Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice.
