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 Frisco Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice is a legal process used to request a change in the location of a scheduled deposition. When filing this motion, the party seeking the change must provide sufficient grounds and justifications for the request. In Frisco, Texas, there are typically two types of Motions for Order that Deposition be taken at a Designated Place other than that Stated in Notice: 1. Emergency Motion: This type of motion is used when unforeseen circumstances arise, making it impossible or impractical to conduct the deposition at the originally specified location. Examples of such circumstances may include severe weather conditions, security concerns, or other unexpected events that pose a risk to the safety or accessibility of the deposition location. The party seeking the emergency motion must demonstrate the urgency and necessity for the change in location. 2. Non-Emergency Motion: This type of motion is filed when there are pre-existing reasons to change the deposition location, such as convenience, cost considerations, or the unavailability of the proposed location on the scheduled date. It is important for the party seeking the non-emergency motion to present valid reasons that outweigh the potential inconvenience or additional costs that might result from changing the deposition location. In order to provide a detailed description of the Frisco Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice, it is essential to highlight the key elements that need to be addressed in the motion: 1. Introduction and Background: Begin by providing a brief introduction to the case, its parties, and the purpose of the motion. Include the relevant details of the deposition notice, including the date, time, and location. 2. Grounds for Change: Clearly state the reasons why a change in the designated deposition location is necessary. If it is an emergency motion, explain the unforeseen circumstances that have arisen and their impact on conducting the deposition. For a non-emergency motion, present the valid reasons that justify the change, such as convenience, unavailability of the proposed location, or cost considerations. 3. Proposed Designated Place: Identify the alternative location where the party is requesting the deposition be held. Ensure that the new location is accessible, suitable, and convenient for all parties involved. If necessary, provide any supporting evidence, such as availability confirmation or rental agreements. 4. Notice to Opposing Parties: Mention the efforts made to inform all opposing parties about the motion and their responses, if any. If there is an opposing party's objection to the motion, address it by providing counterarguments and supporting evidence to strengthen the request for a change in the deposition location. 5. Relief Sought: Clearly state the specific relief requested, which is to have the deposition take place at the designated alternative location proposed in the motion. 6. Conclusion: Summarize the main points of the motion, emphasizing the justifications for the change in deposition location and reiterating the relief sought. By focusing on these elements and incorporating the relevant keywords, such as Frisco, Texas, Motion for Order, Deposition, Designated Place, Notice, Emergency, and Non-Emergency, a detailed description of the required content for the motion can be generated.
