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 Fort Worth, Texas, a Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice is a legal request filed by one party in a lawsuit to change the location of a deposition. This motion is usually filed when the originally specified deposition location no longer suits the interests of the party requesting the change. A deposition is a pre-trial legal procedure where witnesses or parties involved in a case are asked to provide sworn testimony, which can be used as evidence during the trial. The default rule is that a deposition takes place at the location mentioned in the notice provided to the other parties involved. However, when circumstances arise that make it inconvenient or unfair for a deposition to occur at the designated place, a motion can be filed to request a change of location. The Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice typically begins with the identification of the case, court, and parties involved. It should clearly state the original notice's designated location and explain the reasons why it is necessary or more suitable to move the deposition to a different place. Some valid reasons could include: 1. Witness Convenience: If the person being deposed cannot easily travel to the originally designated place due to distance, health conditions, or other personal circumstances, it may be necessary to request a change of location closer to them. 2. Safety Concerns: If there are safety concerns for the witness, such as potential threats or fear of harassment, the party may request a change of location to ensure a secure environment for the deposition to take place. 3. Cost and Efficiency: Sometimes, a change in the deposition location may result in significant cost savings or greater efficiency for all parties involved. This could be due to factors such as reduced travel expenses or a more accessible venue. It is important to note that there may be different types of Fort Worth Texas Motions for Order that Deposition be taken at a Designated Place other than that Stated in Notice, depending on the specific circumstances of the case. For example, a party may file a motion to change the location once, or they may seek multiple changes throughout the course of the litigation as circumstances evolve. In summary, a Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice is a legal request in Fort Worth, Texas, to change the location of a deposition due to valid reasons such as witness convenience, safety concerns, or cost and efficiency.
