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 Waco Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice is a legal motion filed in a court case in Waco, Texas. When a party wants to depose a witness, they typically serve a notice stating the time, date, and place of the deposition. However, circumstances may arise where the designated place is not convenient or suitable for all parties involved. In such situations, a Waco Texas Motion for Order can be filed to request that the deposition take place at a different location. Several types of Waco Texas Motions for Order that Deposition be taken at a Designated Place other than that Stated in Notice may exist, based on the specific reason for the request. Here are some possible variations: 1. Motion for Order of Change of Location: This type of motion is filed when the originally designated deposition location poses logistical challenges. It may argue that the chosen location is too far or inconvenient for one or both parties, or that a different location would better accommodate the needs of the witness or the parties involved. 2. Motion for Order of Safety or Security Concerns: In certain cases, concerns over safety or security might prompt a party to request a change of location for the deposition. This kind of motion highlights specific risks or threats that could arise if the deposition were to take place at the initially specified location. It may include evidence or supporting documents to emphasize the potential dangers involved. 3. Motion for Order of Confidentiality or Privacy: Confidentiality concerns may also lead to a Motion for Order requesting a change of deposition location. If the initial location does not adequately ensure the privacy of the witness or the sensitive information that might be discussed during the deposition, this motion argues for a more suitable and secure location. 4. Motion for Order of Convenience or Efficiency: If the originally designated deposition location poses unnecessary inconvenience or adds unnecessary costs, a Motion for Order can be filed to request a more convenient or cost-effective location. This could be based on factors such as travel distance, available amenities, or the availability of necessary equipment for recording or remote attendance. It is important to note that the specific type of motion and the requirements for filing may vary depending on the court's rules and the circumstances of the case. When filing a Waco Texas Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice, it is crucial to consult local rules, seek legal advice, and provide supporting evidence or arguments to strengthen the motion's chances of success.
