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.
Grand Prairie 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 used in the state of Texas to request a change in the location of a deposition. This affidavit is filed by a party to a lawsuit who believes that it is necessary for the deposition to take place at a different place than the one stated in the original notice. The purpose of this affidavit is to provide detailed and compelling reasons for the change in the deposition location. By submitting this document, the party is asking the court to issue an order allowing the deposition to be conducted at a designated place other than the one mentioned in the notice. There can be various types of Grand Prairie Texas Affidavits in Support of Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice, based on different scenarios and circumstances: 1. Affidavit in Support of Motion for Order to Change Deposition Location Due to Witness Convenience: This type of affidavit is used when the original deposition location is inconvenient for a key witness. The affine provides specific details about the witness's unavailability or difficulties in attending the deposition at the suggested location. 2. Affidavit in Support of Motion for Order to Protect Confidentiality: In cases where sensitive or confidential information might be discussed during the deposition, this affidavit supports the request to change the location to a more secure or private setting. The affine would outline the reasons why the current notice location poses a risk to confidentiality. 3. Affidavit in Support of Motion for Order to Accommodate Special Needs: When a witness or party involved in the lawsuit has special needs or health issues, this type of affidavit is filed to request a change in deposition location that can accommodate those needs. The affine would detail the specific requirements and explain how the original notice location fails to meet them. These are a few examples of the Grand Prairie Texas Affidavit in Support of Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice. Each of these affidavits would outline the facts, justifications, and supporting evidence for the requested change in deposition location. It is important to note that the specific content and structure of the affidavit may vary depending on the unique circumstances of the case. Consulting with a legal professional is advised to ensure compliance with the applicable laws and regulations.
