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.
Carrollton 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 Carrollton, Texas, when a party seeks to request a change in the location of a deposition. This affidavit supports a motion to have the deposition conducted at a different place than initially stated in the deposition notice. Here is an in-depth description of the process and the types of affidavits: 1. Purpose of the Affidavit: The purpose of this affidavit is to provide a detailed explanation to the court, setting forth the reasons why the deposition should be conducted at a designated place other than the one previously noticed. It explicitly states the justifications for the requested change, ensuring transparency and addressing any potential objections from other parties involved. 2. Contents of the Affidavit: The Carrollton Texas Affidavit in Support of Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice typically includes the following information: — Party and case details: The names of the parties involved, their contact information, and the case number. — Description of the deposition notice: A summary of the original deposition notice, including the specified location, date, and time. — Reasons for the requested change: Detailed explanations of the circumstances necessitating the change in the deposition location. This may include logistic challenges, such as cost, convenience, accessibility, or the unavailability of key witnesses or necessary evidence at the original location. — Supporting evidence: Any evidence supporting the argument for the requested location change, such as email exchanges, communication records, or testimonies outlining witness unavailability. — Proposed new location: A specific request for the desired new deposition location, along with its address, date, and time. — Signature and notarization: The affidavit must be signed by the affine, who verifies the truthfulness of the provided information. It is then notarized to add legal validity. 3. Types of Carrollton Texas Affidavit in Support of Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice: While specific names for different variations of this affidavit may not be identified, the content may slightly differ depending on the circumstances. For example: — Affidavit for change in location due to witness unavailability: This affidavit may focus on demonstrating the critical role of unavailable witnesses and how their testimonies are essential to the case. — Affidavit for change in location due to logistical challenges: This affidavit may emphasize the practical challenges associated with conducting the deposition at the original location, such as excessive travel costs or limited accessibility. Overall, Carrollton Texas Affidavit in Support of Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice serves as a formal legal request, detailing the reasons for a change in deposition location and providing supporting evidence. It ensures that all parties involved have an opportunity to present their arguments and have the deposition conducted in a fair and appropriate manner.
