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.
Plano Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice is a legal document filed in Plano, Texas, when a party requests to change the location of a deposition from the originally specified place mentioned in the notice. In such cases, the party must file a Motion for Order, describing the reasons for the requested change and providing sufficient grounds to support the relocation of the deposition. This motion allows the requesting party to present their arguments and convince the court that the deposition should be conducted at a different designated place. Some relevant keywords for this topic could include: 1. Plano, Texas: Referring to the specific geographical location where this motion is filed, highlighting the jurisdiction and legal implications within the area. 2. Motion for Order: A formal request made to the court, asking for a ruling or decision on a specific matter, in this case, the change of deposition location. 3. Deposition: A pretrial legal procedure in which witnesses are questioned under oath, outside the courtroom, during the discovery phase of a lawsuit. 4. Designated Place: The originally stated location for the deposition mentioned in the notice. 5. Notice: The written document sent to involved parties, notifying them of the date, time, and location of the deposition. Different types of Plano Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice could include: 1. Emergency Motion for Order: This type of motion is filed in urgent situations when immediate action is necessary to change the deposition location due to unforeseen circumstances or emergencies. It requires immediate attention from the court to ensure the deposition can proceed smoothly. 2. Standard Motion for Order: This is the most common type of motion filed when a party wants to request a change in the deposition location. It typically involves providing valid reasons and supporting evidence to justify the need for relocation. 3. Motion for Order with Consent of All Parties: In some cases, all involved parties may reach a mutual agreement to change the deposition location. In such instances, a motion can be filed with the consent of all parties involved, making it easier for the court to approve the motion and proceed with the change of location. 4. Motion for Order with Opposing Party Objection: If one party objects to changing the deposition location, they can file an opposition to the motion, expressing their disagreement with the proposed relocation. This scenario may lead to a contested motion, requiring both parties to present their arguments before the court. It's important to note that specific processes and requirements may vary in different jurisdictions. Therefore, it's crucial to consult local laws, court rules, and seek legal advice when filing a Plano Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice.
