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 Mesquite 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 a Texas court to request a change of the location for a deposition. This document is used when the originally scheduled deposition location is inconvenient or impractical for one or both parties involved in the case. It ensures that the deposition can take place at a more appropriate location agreed upon by both parties. Keywords: Mesquite Texas, Affidavit in Support of Motion, Order, Deposition, Designated Place, Notice. Types of Mesquite Texas Affidavit in Support of Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice: 1. Standard Motion for Change of Deposition Location Affidavit: This is the most common type of affidavit filed to request a change in deposition location. It outlines the reasons why the current location is impractical or inconvenient, such as distance, travel costs, or unavailability of necessary resources. 2. Emergency Motion for Change of Deposition Location Affidavit: This type of affidavit is used in urgent situations where a change in deposition location is required immediately due to unforeseen circumstances. It emphasizes the reasons why it is essential to relocate the deposition quickly to ensure the smooth progress of the case. 3. Motion for Change of Deposition Location Affidavit in Response to Objection: This affidavit is filed in response to a party's objection to the originally proposed deposition location. It presents counterarguments to the objections raised by the opposing party, highlighting the benefits and justifications for the requested change. 4. Affidavit Supporting Designated Place for Deposition Based on Accessibility or Expert Availability: In cases where a specific location is essential due to the availability of witnesses or experts, this affidavit is filed. It supports the argument that the deposition should take place at the designated place, emphasizing the significance of the location in carrying out a fair and thorough examination. When drafting a Mesquite Texas Affidavit in Support of Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice, it is crucial to provide clear and compelling reasons for the requested change. The affidavit should state the inconveniences or practicalities experienced with the original location and demonstrate why the proposed designated place is a more suitable alternative. Legal counsel may be advisable to ensure the correct format, terminology, and legal basis are followed when filing the affidavit.
