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.
Collin Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice is a legal motion that allows a party in a lawsuit in Collin County, Texas, to request a change in the location of a deposition. This motion becomes necessary when the location specified in the deposition notice is inconvenient, impractical, or places a burden on the party seeking the motion. The purpose of this motion is to request the court's permission to relocate the deposition to a more convenient or suitable location for all parties involved. This could be due to various reasons such as distance, travel expenses, availability of witnesses or parties involved, or the need for a specific environment or setup. The moving party must provide valid justifications and reasonable arguments for the change of location in the motion. Keywords: Collin Texas, Motion for Order, deposition, designated place, notice, lawsuit, location, change, convenience, impractical, burden, court's permission, relocate, convenient, suitable, distance, travel expenses, witnesses, parties involved, environment, setup. Different types of Collin Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice may include: 1. Collin Texas Motion for Order due to Distance: In this type of motion, the moving party may argue that the designated deposition location is too far away, making it burdensome and costly for the party or witnesses to travel. They might request to change the location to a closer venue, minimizing travel time and expenses. 2. Collin Texas Motion for Order due to Witness Availability: If a vital witness is located in a different area, far from the designated deposition location, the moving party may request a change of location to ensure the witness's presence. They will need to provide evidence or statements explaining the significance and relevance of the witness's testimony. 3. Collin Texas Motion for Order due to Physical Requirements: Sometimes, specialized equipment or a specific environment may be required for the deposition. In such cases, the moving party can request a change of location to accommodate these needs. This motion will require supporting documentation or expert opinions justifying the necessity for the designated place. 4. Collin Texas Motion for Order due to Safety Concerns: In situations where safety concerns, such as threats or risks to individuals involved in the deposition, exist, the moving party can request a change of location to ensure everyone's well-being. They will need to provide credible evidence or testimonials supporting their claims. 5. Collin Texas Motion for Order due to Inconvenience or Impracticality: If holding the deposition at the designated location presents practical difficulties that significantly hinder the parties involved, the moving party can request a change of location. This may include factors like unavailability of necessary facilities, scheduling conflicts, or logistical issues. It is important to note that each type of motion will require its specific supporting documents, such as affidavits, expert opinions, or any relevant evidence, to strengthen the arguments. The court will evaluate the motion, weigh the reasons presented by the moving party against the opposing party's interests, and make a decision accordingly.
