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.
Title: Understanding Irving Texas Motion for Order that Deposition be Taken at a Designated Place other than that Stated in Notice Introduction: The Irving Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice is a crucial legal procedure that allows parties to request a change in the deposition location. This detailed description aims to explain the motion, its significance, and potential variations. Keywords: Irving Texas Motion for Order, deposition, designated place, Notice, legal procedure, change, location, variations. 1. Definition of Irving Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice: The Irving 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 one party to relocate the scheduled deposition to a different location than initially stated in the notice. This motion enables flexibility and convenience for the participants involved in the deposition process. 2. Importance of the Motion: By allowing the parties to request a change of deposition location, the Irving Texas Motion for Order ensures efficiency, fairness, and accessibility during the legal proceedings. It acknowledges that unforeseen circumstances or practical concerns may arise, making it difficult to stick to the initially designated place for the deposition. 3. Justifying the Motion: To successfully obtain an Irving Texas Motion for Order, the requesting party must provide valid reasons justifying the need for a change in deposition location. Valid justifications can include the unavailability of the initially designated location, geographic proximity to key witnesses or evidence, the convenience of the parties involved, or concerns related to safety or security. 4. Potential Types of Irving Texas Motion for Order: The Irving Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice can have different variations based on the specific requirements or circumstances of the case. Some possible variations may include: a. Emergency Motion for Order: This variation of the motion is applicable when unforeseen circumstances arise that make it impossible or impractical to continue with the deposition at the initially designated place. Urgent factors, such as natural disasters, emergencies, or sudden cancellations of venue bookings, may necessitate an emergency motion. b. Geographic Convenience Motion for Order: This type of motion is filed when relocating the deposition to a designated place that offers better geographic convenience for the parties involved. This may be due to long travel distances, the accessibility of key witnesses or evidence, or other logistical considerations. c. Safety and Security Motion for Order: If there are concerns regarding safety or security at the initially designated deposition location, this particular motion seeks to request a change to a designated place that guarantees the safety and security of the participants. Conclusion: The Irving Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice is a legal procedure that allows parties flexibility in adapting to changing circumstances. By understanding this motion and its potential variations, parties can navigate the deposition process more efficiently, ensuring a fair and smooth legal proceeding.
