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.
A McAllen Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice is a legal document filed by one party in a lawsuit requesting a change in the location of a deposition. This motion is typically filed when the original location stated in the notice is inconvenient, impractical, or would cause undue hardship for the deponent or the parties involved. Keywords: McAllen Texas, motion for order, deposition, designated place, notice, lawsuit, legal document, change, location, inconvenience, impracticality, undue hardship. Types of McAllen Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice: 1. Motion based on geographic distance: This type of motion is filed when the location stated in the notice is too far from the deponent's residence or office, causing significant travel time and expenses. The moving party will argue that holding the deposition at a designated place closer to the deponent will serve the interests of fairness and convenience. 2. Motion based on accessibility or accommodations: In certain cases, the originally stated location may not meet the necessary accessibility requirements or may lack appropriate accommodations for the deponent. This type of motion would argue for a change of location to a designated place that can provide necessary facilities, such as wheelchair accessibility or specialized equipment. 3. Motion based on safety concerns: If the deponent or the parties involved have valid safety concerns regarding the originally stated location, a motion may be filed to change the deposition site. This could arise in situations where the deponent fears personal harm or feels uncomfortable in the initial location due to potential conflicts or threats. 4. Motion based on privacy or confidentiality: If the originally stated location poses a risk to maintaining the privacy or confidentiality of the deposition, a motion can be filed to request a change. This could be the case when sensitive or confidential information is likely to be discussed during the deposition, and the original location lacks appropriate measures to protect such information. Overall, a McAllen Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice allows parties in a lawsuit to request a change of deposition location when there are valid reasons such as geographic distance, accessibility, accommodations, safety concerns, or privacy and confidentiality issues.
