Fill and Sign the Texas Order Place Form

IN THE __________COURT OF ________________ (Name of County) STATE OF ______________ (Name of State) ______________________ PLAINTIFF (Name of Plaintiff) VS. CAUSE NO. ___________ ______________________ DEFENDANT ______________________ (Names of Defendants) Motion for Protective Order Comes now ___________________ (Name of Defendant) , 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 De position noticed for oral examination be taken only on written questions. As ground for said Motion, Defendant states: 1. On ______________ (date) , ________________ (Name of Plaintiff) , the Plaintiff herein, filed this Action against Defendants. 2. On _______________ (date) , _________________ (Name of Attorney) , 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 __________________________ (Name of City and State) . 4. Defendant 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 Defendant to travel and stay in __________________ (Name of City) , Texas, where the Deposition is presently notices to be taken. 6. Both of the parents of Defendant live in _____________________ (Name of City and State) , and depend on Defendant daily for their well-being. Defendant’s Father ____________________ (Name of Father) had a stroke in __________ (year) and still suffers from the result of it with states of confusion. Defendant’s Mother ___________________ (Name of 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 _________________________ (Name of City and State) to take Defendant’s Deposition and examine documents. 8. T he matters on which Plaintiff desires to interrogate this Defendant are relatively simple and can be effectively ascertained by means of written questions . 9. Defendant ha s in good faith conferred or attempted to confer wit ______________________________ (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. This motion will be based on this written Motion and Notice, on the Affidavit of ______________________ (Name of Defendant) attached to this Motion , and on all the pleadings, papers, records, and files in this action. Respectfully submitted, _______________________ (Printed Name of Defendant) _______________________ (Signature of Defendant) 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 Motion 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) Notice of Motion for Protective Order You are notified that on __________________ ( date) , at ___________ (time) , or as soon thereafter as Defendant can be heard, in Courtroom ______ of the ____________Court for _____________ County, _______________ (State) , at the ________________ (County) Courthouse at _______________________ __________________________________________________ (street address, city, county, state, zip code) , Defendant will bring on for hearing her Motion for the reasons stated in the above Motion. Respectfully submitted, _______________________ (Printed Name of Defendant) _______________________ (Signature of Defendant)