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 Pasadena Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice is a legal motion filed in the Pasadena area of Texas when a party believes that the designated place for a deposition is not appropriate or convenient. This motion is typically filed when there are justifiable reasons for a change in the deposition location, such as the unavailability of the original location, geographic constraints, or potential hardship on the party or witnesses involved. There are different types of Pasadena Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice, depending on the specific circumstances of the case. Some common variations may include: 1. Motion for Order to Change Deposition Location: This type of motion is filed when a party seeks to change the deposition location due to factors such as scheduling conflicts, distance, or logistical challenges. The moving party must demonstrate to the court that the change in the designated place would be more reasonable and equitable. 2. Motion for Order to Move Deposition Within the Same Jurisdiction: In some cases, a party may request to change the deposition location within the same jurisdiction. This motion may be filed when there is a need to relocate the deposition within Pasadena, Texas, but to a different location that better serves the interests of the parties involved. 3. Motion for Order to Change Deposition Location to Another Jurisdiction: When the original designated place for deposition is outside of Pasadena, Texas, but still within the state, a party may file a motion requesting a change in the deposition location to Pasadena. This type of motion is common when the party believes that it would be more convenient or appropriate for the deposition to take place in Pasadena rather than the initially designated location. The Pasadena Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice is an important legal tool that allows parties to seek a change in the deposition location when warranted. By filing such a motion, parties can ensure that depositions are conducted in a fair and reasonable manner, considering the practical aspects and constraints associated with the case at hand.
