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 McKinney Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice is a legal document that allows a party involved in a lawsuit to request a change in the location of a scheduled deposition. This motion is filed when the designated place stated in the deposition notice is either inconvenient or impractical for the party requesting the change. There can be various types of McKinney Texas Motions for Order that Deposition be taken at a Designated Place other than that Stated in Notice, including: 1. Emergency Motion: This type of motion is filed when unforeseen circumstances arise that make it extremely difficult or impossible for the party to attend the deposition at the originally stated location. Examples could include sudden illness, severe weather conditions, or unexpected travel restrictions. 2. Hardship Motion: A hardship motion is filed when attending the deposition at the designated location would cause undue hardship for the party being deposed. This could include significant travel expenses, extreme distance, or other compelling reasons that make attending the deposition at the original location impractical. 3. Safety Concern Motion: If the party being deposed has legitimate concerns for their safety or security at the designated location, they can file a motion to request a change in the deposition location. This could occur in cases where there is a history of threats, harassment, or potential danger. 4. Accessibility Motion: This type of motion is filed when the designated location is not accessible to the party being deposed due to disability or physical limitations. In such cases, the party may request that the deposition be moved to a location that is more accommodating and accessible. In all these motions, it is crucial to provide detailed and factual evidence supporting the reason for the requested change in deposition location. The party filing the motion must clearly outline why the current designated place is unsuitable and propose an alternative location that would be more convenient or appropriate. A judge will then review the motion and determine whether the request is warranted and grant an order to change the deposition location if deemed appropriate.
