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.
The Edinburg Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice is a legal procedure that allows the party requesting the deposition to propose an alternative location for the deposition to take place. This motion is utilized when the originally scheduled location may not be convenient or feasible for one or both parties involved. In Edinburg, Texas, there are a few distinct types of Motions for Order that Deposition be taken at a Designated Place other than that Stated in Notice. These include: 1. Motion to Change Deposition Location: This type of motion is typically filed when the current deposition location, as stated in the notice, poses a hardship or inconvenience for one or both parties involved. Reasons for requesting a change in location may include distance, accessibility, or travel-related complications. 2. Motion for Secure or Confidential Location: In certain cases, the nature of the deposition may require special considerations for privacy or security reasons. This type of motion is filed to propose a designated place for the deposition that ensures the protection and confidentiality of sensitive information or when dealing with particularly sensitive subject matters that necessitate added security measures. 3. Motion to Accommodate a Witness or Party: Sometimes, a witness or party involved in the deposition may face physical or medical limitations that make attending the originally designated location challenging or impossible. In such cases, a motion can be filed to propose an alternative location that can accommodate the needs of the individual involved. It is crucial to note that these motions must be supported by valid reasons and typically require the court's approval. The requesting party must present a persuasive argument demonstrating why the change in location is necessary and justifiable. In conclusion, the Edinburg Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice serves as the legal mechanism to request a change in deposition location based on various circumstances such as convenience, privacy, security, or accommodating specific parties or witnesses.
