Fill and Sign the Texas Designated Form

Affidavit in Support of Motion for Order that Deposition be taken at a Designated Place other than that Stated in Notice IN THE __________COURT OF (Name of County) STATE OF TEXAS (Name of Plaintiff) PLAINTIFF VS. CAUSE NO. __________ (Names of Defendants) DEFENDANT 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. T he matters on which Plaintiff desires to interrogate Affiant are relatively simple and can be effectively ascertained by means of written questions . 9. Affiant ha s 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)