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 Pasadena 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 requests a court order to change the location of a deposition. This affidavit is applicable in the jurisdiction of Pasadena, Texas. When a deposition is scheduled, it is usually held at a specific location mentioned in the notice. However, circumstances may arise that necessitate a change in the designated place due to various factors such as convenience, witness availability, or exceptional circumstances. In such cases, the party requesting the change must file an affidavit in support of their motion. The Pasadena 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: 1. Heading: Affidavit in Support of Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice. 2. Title of the Court: The name of the court where the motion is being filed, usually a district or county court in Pasadena, Texas. 3. Case Details: The specific case details, including the names of the parties involved, case number, and relevant dates. 4. Affine Details: The details of the affine who is submitting the affidavit, including their name, address, contact information, and their role in the case (e.g., plaintiff, defendant, or witness). 5. Motion Details: A clear statement explaining that the affine is seeking a court order to change the location of the deposition stated in the original notice. 6. Reasons for the Change: A detailed explanation justifying the need for the change of location. This may include factors such as the unavailability of the original location, interference with witness availability, or personal circumstances that necessitate a change. 7. Proposed Alternative Location: The affine should specify the desired alternative location where they propose the deposition to take place. 8. Supporting Evidence: The affine may provide supporting evidence and documentation to back up their reasons for seeking a change in location. This may include witness statements or documents confirming the unavailability of the original location. 9. Sworn Statement: The affidavit should conclude with a sworn statement by the affine, attesting to the truthfulness and accuracy of the information provided. Different types of Pasadena Texas Affidavit in Support of Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice may vary based on the specific circumstances and requirements of each case. Some variations may arise due to the type of case (e.g., civil or criminal), the court jurisdiction, or any specific local rules that must be followed. It is essential to consult with a legal professional and thoroughly review the relevant statutes, rules, and procedures specific to Pasadena, Texas, when drafting and filing this affidavit.
