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.
Laredo 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 in a case to request a change in the location of a deposition. This motion is filed when there is a need to move the deposition to a more suitable or convenient location for one or both parties involved. In Laredo, Texas, there may be several types of motions for order that the deposition be taken at a designated place other than that stated in the notice. Some of these motions may include: 1. Motion for Order to Change Deposition Venue: This type of motion is filed when one party requests that the deposition be conducted in a different location due to factors such as distance, accessibility, or convenience. 2. Motion for Order to Move Deposition for Witness's Convenience: This motion is filed when the witness or a party involved has legitimate reasons to request a change in the deposition location for their convenience. These reasons may include medical conditions, inability to travel long distances, or other personal circumstances. 3. Motion for Order to Move Deposition due to Safety Concerns: If there are concerns about the safety or security of conducting the deposition at the initially designated place, this motion can be filed to request relocation to a new venue that ensures the protection of all parties involved. 4. Motion for Order to Accommodate Disabilities: If a party or witness has a disability that makes it difficult or impossible to attend the deposition at the stated location, a motion can be filed to request a change in venue to accommodate their needs. 5. Motion for Order to Move Deposition for Economic Reasons: This type of motion is filed when the cost of conducting the deposition at the initially designated place is excessively high or impractical. Parties may request a change in location to reduce expenses or ensure more equitable distribution of financial burdens. When filing a Laredo Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice, it is important to provide detailed justifications, supporting evidence, and proposed alternative locations. The court will review the motion and make a decision based on the merits of the request and the interests of justice.
