Civil No Contact Order Polk County Iowa

Motion for Protective Order

IN THE COURT OF

STATE OF

PLAINTIFF

VS. CAUSE NO.

DEFENDANT

Motion for Protective Order

Comes now , one of the Defendants, in the above-captioned cause, who moves the Court, pursuant to Rule 192.6(b)(3) of the Texas Rules of Civil Procedure, to Order that a Deposition be taken in the City and State where Defendant lives, or, in the alternative, Defendant moves pursuant to Rule 192.6(b)(4) of the Texas Rules of Civil Procedure, that the Deposition noticed for oral examination be taken only on written questions. As ground for said Motion, Defendant states:

1. On , , the Plaintiff herein, filed this Action against Defendants.

2. On , , Attorney for Plaintiff forwarded to this Defendant a Deposition Subpoena Duces Tecum, a copy of which is attached as Exhibit A to this Motion.

3. Defendant lives and works in .

4. Defendant works as a , on the average, hours per day as a necessity since is short handed due to (reason)

5. It would cause a severe financial hardship on Defendant to travel and stay in , Texas, where the Deposition is presently notices to be taken.

6. Both of the parents of Defendant live in , and depend on Defendant daily for their well-being. Defendant’s Father had a stroke in and still suffers from the result of it with states of confusion. Defendant’s Mother also suffers from ill health and is bedridden. Both depend on Defendant to make sure that they take their medications on a timely basis.

7. Defendant avers that Plaintiff is in a better situation financially and otherwise to have his Attorney travel to to take Defendant’s Deposition and examine documents.

8. The matters on which Plaintiff desires to interrogate this Defendant are relatively simple and can be effectively ascertained by means of written questions.

9. Defendant has in good faith conferred or attempted to confer wit , the Attorney for Plaintiff , in an effort to resolve the dispute without Court action, but such effort was unproductive.

This motion will be based on this written Motion and Notice, on the Affidavit of attached to this Motion, and on all the pleadings, papers, records, and files in this action.

Respectfully submitted,

Certificate of Service

This is to certify that I, , a Defendant in the above Action, have this date served a true and correct copy of the above and foregoing Motion by U.S. Mail, postage fully prepaid, to the following counsel of record for the Plaintiff:

This the day of , 20 .

Respectfully submitted,

Notice of Motion for Protective Order

You are notified that on , at , or as soon thereafter as Defendant can be heard, in Courtroom of the Court for County, , at the Courthouse at , Defendant will bring on for hearing her Motion for the reasons stated in the above Motion.

Respectfully submitted,