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.
Dallas Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice is a legal motion filed in the state of Texas when a party wishes to have a deposition conducted at a location other than the one specified in the notice. This motion allows for flexibility in arranging the deposition process to accommodate the needs of both parties involved. When filing a Dallas Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice, it is important to include the following relevant keywords and details: 1. Party names: Provide the names of the parties involved in the case, including the plaintiff and defendant. 2. Case number: Include the specific case number assigned to this particular litigation. 3. Notice details: Mention the details of the initial deposition notice, including the date, time, and location as stated in the notice. 4. Reason for the motion: Clearly explain the reasons why the deposition needs to be conducted at a different location. This may include logistical issues, travel constraints, safety concerns, or any other valid justification. 5. Proposed designated place: Specify the desired location for the deposition, providing the complete address and any other necessary information. 6. Availability and cooperation: Highlight the party's willingness to cooperate in scheduling the deposition at the proposed designated place and assure their availability for the agreed-upon date and time. 7. Legal basis: Cite relevant Texas laws or court rules supporting the motion for conducting the deposition at a different location. This may include references to specific statutes or procedural rules governing depositions. 8. Notice: Explain how the opposing party has been properly served with this motion for their review and response within the stipulated timeframe. It is important to note that there are no specific types of Dallas Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice. However, different variations of this motion may arise based on the specific circumstances and reasons for requesting a change in the deposition location.
