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 McAllen 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 that allows a party in a court case to request a change in the location of a deposition. It provides a detailed explanation of the reasons for this request and must be filed with the court. The affidavit serves as a persuasive tool for the party seeking the change in deposition location and must demonstrate valid grounds for the requested alteration. It typically contains specific keywords that make it relevant and informative to the court. Some essential keywords to include in the affidavit are: 1. McAllen Texas Court: This keyword specifies the jurisdiction where the motion is being filed, ensuring that the court understands the authority under which the affidavit is submitted. 2. Motion for Order: This keyword highlights the purpose of the affidavit, which is to request a change in the deposition location. It emphasizes the need for an order from the court to make the desired modification. 3. Deposition: Referring to the legal process of obtaining sworn testimonies from witnesses or parties involved in a case, the keyword underlines the subject of the motion, indicating that the requested change is related to a deposition. 4. Designated Place: This keyword emphasizes the current location mentioned in the initial notice for the deposition. It clarifies that the party is seeking an alternative location. The McAllen Texas Affidavit in Support of Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice may have different variations based on the specific circumstances of the case. For instance: 1. Emergency Motion: If unexpected circumstances arise after the original notice, such as a witness's sudden unavailability, the party may file an emergency motion to change the deposition location promptly. 2. Disputing Party's Request: If the party being deposed disagrees with the initial location proposed in the notice, they may file a motion to change the deposition venue. 3. Witness Convenience: If the current location presents significant disruption or undue hardship for a witness, the party that called the witness may submit a motion to change the deposition location for the witness's convenience. 4. Safety Concerns: If there are valid concerns regarding the safety of the parties involved or if the current location poses a risk, the affected party can submit an affidavit to request a change in deposition venue. In conclusion, the McAllen Texas Affidavit in Support of Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice is a crucial legal document that allows a party to request a change in the deposition location. It should contain relevant keywords and may have different types based on the specific circumstances of the request.
