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A motion to quash asks the court to confirm that you don't have to respond to a discovery request. In this case, the motion asks the court to confirm that you don't have to respond to discovery you received before the deadline for initial disclosures.
Motion to quash Before filing the motion, you must do two things: (1) serve written objections to the deposition notice; and (2) meet and confer with opposing counsel before filing the motion. If you file a motion to quash, the deposition is automatically stayed pending the court's ruling. (§ 2025.410(c).)
Rule 199.4 of the Texas Rules of Civil Procedure provides that ?[a] party may object to the time and place designated for an oral deposition by motion for protective order or by motion to quash the notice of the deposition.
Section 159.105 - Motions to Quash or for Protective Order (a) On behalf of a subpoenaed witness, a party may move to quash a subpoena or for a protective order. A party that moves to quash a subpoena must serve the motion on the other party at the time the motion is filed with SOAH.
If the motion is filed by the third business day after service of the notice of deposition, an objection to the time and place of a deposition stays the oral deposition until the motion can be determined.