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 Killeen Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice is a legal procedure that allows a party in a lawsuit to request a change in the location of a deposition. This motion is usually filed when the original designated place for the deposition is inconvenient or impractical for one or both parties involved. The primary purpose of this motion is to ensure that the deposition can occur in a more suitable location, taking into consideration various factors that may impact the effectiveness and efficiency of the proceedings. It allows the requesting party to present valid reasons for the change and seek approval from the court. There are different types of Killeen Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice, including: 1. Motion to Change Deposition Location due to Witness Unavailability: In some cases, a witness's unavailability or inability to travel to the originally intended deposition location necessitates the filing of this motion. Valid reasons may include medical conditions, scheduling conflicts, travel restrictions, etc. 2. Motion to Change Deposition Location for Convenience of the Parties: This type of motion is commonly filed when the original designated place is inconvenient or burdensome for one or both parties. Factors such as distance, transportation accessibility, availability of legal representation, and financial constraints may be taken into consideration when requesting a change of location. 3. Motion to Change Deposition Location for Safety Concerns: Occasionally, concerns related to the safety and security of one or more parties involved in the deposition may arise. This motion allows the requesting party to present compelling reasons why the originally designated place is deemed unsafe and provides alternatives to ensure a secure environment for the proceedings. It is important to note that the granting of a motion for a change in deposition location is at the discretion of the court. The requesting party must provide sufficient evidence and persuasive arguments to justify the need for the change. By filing this motion, the party demonstrates their commitment to ensuring a fair and efficient deposition process, taking into account the particular circumstances of the case.
