A motion to quash filed by the third business day after the notice is served stays the deposition automatically — no hearing, no order, nothing to prove yet. Filed on the fourth day, that stay is gone and the argument has to carry it instead.
Both routes are workable. They are not the same case, and the difference is a date.
How did the deposition notice reach you?
The rule runs from service, so this is the question that decides everything that follows.
The county decides which court of appeals binds your trial judge, and that decides which line of authority we argue from. Two identical motions in two counties are not the same motion.
We hold the published Texas case law in our own index and query it directly. No vendor sits between the question and the answer. That is the reason a discrete motion can carry a price on a web page instead of an hourly rate and a hope.
Pulled from our index for this mechanism and read by a lawyer before it went on this page. A green check means the decision is on point for this posture. It is not a statement that the case has been shepardized, and it is not a representation about its current precedential standing.
Counts are the number of later decisions in our index that cite the case. A high count means a case has been used, not that it is good law. Nothing on this page is a citator signal and we will not show one until it is produced by reading opinions rather than counting them.
Rule 199.4's automatic stay has a three-day window. Rule 192.6 protective relief has no window at all — it can be sought at any time before the deposition, and it reaches further than time and place. It reaches the topics, the scope, the manner and whether the deposition happens at all. This is the posture where the argument does the work the calendar used to do, and it is the posture where getting it right the first time is worth the most.
If the stay is gone, the file matters more than the calendar. Any of these moves the analysis — and all of them are usually in documents you already have.
On a corporate representative notice the topic list is where most of these are won. A designation of "all communications" with no subject and no date range is not a designation.
Whether a lower-level witness has already been deposed on the same subjects is often the entire apex argument, and it is the first thing a court asks.
A record showing you offered dates and were ignored reads very differently from a record showing you went quiet. Courts weigh this heavily.
Where the discovery period closes, and what is set immediately after the deposition, changes what relief is realistic to ask for.
Or send nothing but the notice and let us find the rest. Dropping the file at the top of this page is the whole first step.
We will read it and tell you what we would do if we represented you on this single task — what we would file, on what ground, and what it would cost to have us do it.