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.
The Austin 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 by a party in a court case to request that a deposition, which is a pre-trial oral testimony of a witness, be taken at a specific location other than the one originally stated in the notice. This affidavit is used when there is a need to change the deposition location due to various reasons, such as the convenience of the witness or the parties involved, the location of evidence or documents, or the accommodation of physical or medical limitations of a party or a witness. The affidavit provides the court with justifications for the requested change in location and is typically supported with relevant facts and evidence. The affidavit should be detailed and include specific keywords that describe the reasons for the requested change in deposition location, such as: 1. Convenience: If the current deposition location would cause undue inconvenience or hardship on the deponent, the affidavit should outline the specific reasons why the requested location is more convenient. 2. Evidence or Documents: If there is specific evidence or documents that are necessary for the deposition and are located at another place, the affidavit should explain the importance of having access to those materials during the deposition. 3. Physical or Medical Limitations: If a party or a witness has physical or medical limitations that prevent them from attending the deposition at the originally stated location, the affidavit should provide medical documentation or other evidence supporting the need for a change in location. There may not be different types of Austin Texas Affidavit in Support of Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice, as this is a specific document used for a particular purpose. However, the content and language of the affidavit may vary depending on the specific circumstances and reasons for the requested change in location. It is important to consult with an attorney or legal professional in Austin, Texas to ensure that the affidavit complies with local court rules and requirements. The attorney can provide guidance on the specific format, wording, and supporting documentation necessary for the affidavit to be considered valid and persuasive by the court.
