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.
Lewisville Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice is a legal procedure sought by one party involved in a case to request the court to allow the deposition to be taken at a location different from the one initially stated in the notice of deposition. This motion can be filed when there are valid reasons or circumstances that make it impractical or unfair to conduct the deposition in the originally designated place. In Lewisville, Texas, there are a few different types of motions for an order that deposition be taken at a designated place other than that stated in the notice: 1. Motion for Change of Venue: This type of motion can be filed when the party seeking the deposition believes that the original location specified in the notice is not convenient, suitable, or accessible for proper examination of the deponent. The motion requests the court to change the venue to a more appropriate location. 2. Motion for Protective Order: This type of motion is typically filed when the party seeking the deposition believes that the originally stated place poses a risk or threat to the safety, privacy, or well-being of the deponent. The motion requests the court to order the deposition to be held at a designated place that ensures the protection and comfort of the deponent. 3. Motion for Convenience: This type of motion is filed when the originally stated deposition location is deemed inconvenient for one party involved in the case. Reasons may include distance, costs, or other practical considerations. The motion seeks permission from the court to relocate the deposition to a more convenient location for all parties involved. These various types of motions allow the party seeking the deposition to present valid arguments to the court and ensure that the deposition takes place in a location that is fair, convenient, and conducive to a thorough examination. It is important to note that each motion must provide strong and justifiable reasons to support the request for a change in the designated deposition place. In summary, a Lewisville Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice allows one party to request the court to relocate the deposition to a more appropriate, secure, or convenient location. Several types of motions can be filed under this category, including a motion for change of venue, a motion for protective order, and a motion for convenience. Each motion necessitates substantial justification to support the request for a change in location.
