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.
Houston Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice refers to a legal request made by a party involved in a lawsuit or trial within the Houston, Texas jurisdiction. This motion seeks permission from the court to conduct a deposition at a location other than the one initially designated in the notice. Depositions are an important part of the discovery process in a lawsuit, where witnesses or parties are required to provide testimonies under oath, which can later be used as evidence in court. Generally, the location for a deposition is determined by the notice sent to the parties involved, specifying the time, date, and place where the deposition will take place. However, circumstances may arise where conducting the deposition at the initially designated location would be impractical or inconvenient for various reasons. In such cases, a party may file a Houston Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice. This motion should contain relevant keywords that comply with legal terminology and clearly state the reasons justifying the need for a change in deposition location. Relevant keywords for this motion could include "motion," "order," "deposition," "designated place," "Houston," "Texas," "stated in notice," and "designated place." There may be various types or situations that could warrant filing this motion. For example: 1. Unavailability of key witnesses — If a witness crucial to the case cannot appear at the designated location due to illness, travel restrictions, or other valid reasons, the party requesting the change in deposition location may file this motion. 2. Safety concerns or security issues — If conducting the deposition at the initially designated location poses a risk to the safety or security of the parties involved, such as in cases involving threats or harassment, this motion may be filed. 3. Practicality and convenience — In certain situations, it may be more convenient or practical to conduct the deposition at a different location. For instance, if all the parties are located in a different city or state, and it would be excessively burdensome or costly to travel to the initially designated location, this motion can be filed. In conclusion, a Houston Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice is a formal request made to the court to change the location of a deposition from the one initially specified in the notice. This motion can be filed in different situations where it would be impractical, inconvenient, or unsafe to conduct the deposition at the original location.
