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.
An Abilene Texas Affidavit in Support of Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice is a legal document filed in the Texas state court system. This affidavit is used when a party to a lawsuit wants to request a change in the location where a deposition should take place. By filing this affidavit, the party is seeking an order from the court to allow the deposition to occur at a location different from the one initially stated in the notice. Keywords: Abilene Texas, affidavit, support, motion, order, deposition, designated place, notice. There are two primary types of Abilene Texas Affidavit in Support of Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice: 1. Emergency Motion: This type of affidavit is filed when the party requesting the change in the deposition location believes that there is an urgent need to do so, such as when a crucial witness is unavailable for the previously scheduled location. The party must present a valid reason to justify the emergency status of the motion. 2. Non-Emergency Motion: In cases where the need to change the deposition location is not immediate or time-sensitive, a non-emergency motion is filed. This allows both parties involved in the lawsuit to properly prepare for the requested change and address any potential concerns or objections. When drafting an Abilene Texas Affidavit in Support of Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice, it is important to include the following details: 1. Case information: Provide the full name and number of the case, as well as the names and contact information of all parties involved. 2. Background and context: Explain the reasons why you are seeking a change in the deposition location. Provide a clear and concise overview of the circumstances that necessitate the change. 3. Details of the current deposition location: State the originally designated place where the deposition was scheduled to take place, highlighting any deficiencies or challenges associated with that location. 4. Proposed alternative location: Identify the preferred alternative location for the deposition and explain why it would be more suitable or convenient for all parties involved. Provide relevant information about the proposed location, such as its proximity to relevant parties or the availability of necessary equipment. 5. Supporting evidence: Attach any supporting documents or evidence that substantiate your request, such as witness statements, correspondence, or logistical information. 6. Legal basis: Present the legal grounds for your motion, citing relevant statutes, rules, or case law that support your argument for a change in the deposition location. In conclusion, an Abilene Texas Affidavit in Support of Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice is a vital legal document used to request a change in the location of a deposition. It is necessary to provide a detailed explanation of the circumstances, propose a suitable alternative location, and provide supporting evidence to strengthen the motion.
