Fill and Sign the Name in the United States District Court for the Eastern Form

IN THE __________COURT OF ______________ (Name of County) STATE OF ________________ (Name of State) ____________________ PLAINTIFF (Name of Plaintiff) VS. CAUSE NO. _____________ _____________________ DEFENDANT _____________________ (Names of Defendants) Affidavit in Support of Motion for Protective Order STATE OF ____________________ COUNTY OF __________________ PERSONALLY appeared before me, the undersigned authority in and for said county and state, ___________________ (Name of Affiant), who, having been being first duty sworn by the undersigned Notary Public, deposes and says: 1. On _________________ (date), __________________ (Name of Plaintiff) , the Plaintiff herein, filed this Action against Affiant. 2. On ________________ (date), ____________________ (Name of Attorney) , Attorney for Plaintiff forwarded to Affiant a Deposition Subpoena Duces Tecum, a copy of which is attached as Exhibit A to this Affidavit. 3. Affiant lives and works in ______________________ (Name of City and State). 4. Affiant works as a _________________ (Name of Occupation), on the average, ______ hours per day as a necessity since _____________________ (Place of Occupation) is short handed due to (reason) _________________________________ _____________________________________________________________________ . 5. It would cause a severe financial hardship on Affiant to travel and stay in _________________ (Name of City), Texas, where the Deposition is presently noticed to be taken. 6. Both of the parents of Affiant live in __________________________ (Name of City and State) , and depend on Affiant daily for their well-being. Affiant’s Father ____________________ (Name of Father) had a stroke in ____________ (year) and still suffers from it such in that he has states of confusion. Affiant’s Mother __________________ (Name of Mother) also suffers from ill health and is bedridden. Both depend on Affiant to make sure that they take their medications on a timely basis. 7. Affiant believes that Plaintiff is in a better situation financially and otherwise to have his Attorney travel to _________________________ (Name of City and State) to take Affiant’s Deposition and examine documents. 8. The matters on which Plaintiff desires to interrogate Affiant are relatively simple and can be effectively ascertained by means of written questions. 9. Affiant has in good faith conferred or attempted to confer with _______________ (Name of Attorney) , the Attorney for Plaintiff _________________ (Name of Plaintiff) , in an effort to resolve the dispute without Court action, but such effort was unproductive. ______________________________ (Printed Name of Affiant)______________________________ (Signature of Affiant) SWORN to and subscribed before me, this the ______ day of ______________, 20______. _______________________ NOTARY PUBLIC My Commission Expires: ___________________ Certificate of Service This is to certify that I, __________________ (Name of Defendant) , a Defendant in the above Action, have this date served a true and correct copy of the above and foregoing Affidavit by U.S. Mail, postage fully prepaid, to the following counsel of record for the Plaintiff: _______________________(Name of Attorney) __________________________________ (Post Office Box No. or Street Address) ___________________________________ (City, State, Zip Code) This the ____day of ____________________, 20_____. Respectfully submitted,_______________________ (Printed Name of Defendant)_______________________ (Signature of Defendant)