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 Brownsville 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 with the court to request a change in the location of a deposition. This affidavit outlines the reasons why the deponent, or the party seeking the deposition, believes that an alternative location would be more appropriate or convenient for the deposition proceedings. Keywords: Brownsville Texas, Affidavit, Motion for Order, Deposition, Designated Place, Notice. There are various types of Brownsville Texas Affidavit in Support of Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice, and they can be named based on the specific circumstances involved. Here are a few examples: 1. Affidavit in Support of Motion for Order that Deposition be taken at a Designated Place due to Witness Unavailability: This type of affidavit is filed when a witness who is vital to the case, but is unable to attend the deposition at the originally noticed location due to factors such as health issues, distance, or prior commitments. The affidavit will provide details on the witness's unavailability and explain why a designated place should be considered. 2. Affidavit in Support of Motion for Order that Deposition be taken at a Designated Place for the Convenience of the Parties: When the originally noticed location poses logistical challenges for one or both parties involved in the deposition, this affidavit can be filed. The affine will provide reasons and evidence supporting the claim that moving the deposition to a different designated place would be more convenient for all parties involved. 3. Affidavit in Support of Motion for Order that Deposition be taken at a Designated Place to Ensure Witness Safety: In certain cases, the safety of a witness may be a concern, necessitating a change in the deposition location. This affidavit will outline the specific threats or concerns that justify the need for a designated place that ensures the witness's safety and wellbeing during the deposition process. 4. Affidavit in Support of Motion for Order that Deposition be taken at a Designated Place to Accommodate Special Needs or Accessibility Issues: If a deponent or any party involved in the deposition has special needs or requires specific accessibility accommodations, this affidavit can be filed. It will detail the specific needs or issues and explain why a designated place is necessary to ensure equal participation and a fair deposition process. These examples highlight some different types of Brownsville Texas Affidavit in Support of Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice, each addressing unique circumstances that may require a change in the deposition location.
