Court Rules
Judge Drew B. Tipton
Judge

Judge Drew B. Tipton

Individual Rules, Standing Orders & Policies

Southern District of Texas

Limits & Logistics

Document Limits

Letter
2 pgs
Supplemental Brief
10 pgs
Letter
3 pgs

Courtesy Copies

Courtesy copies

  • 2 copies • At Trial Hearing
  • 2 copies • Ready For Court During Trial
  • Email

Emergency Motion

  • 1 copy • Email • Immediately Upon Filing

Exhibit

  • Within Seven Calendar Days

Exhibits

  • Seven Calendar Days After Joint Pretrial Order Filed

Adjournments

  • Motions to extend discovery deadlines must be filed sufficiently early to allow opposing counsel to respond before the original deadline.
  • Extension requests must obtain court permission before submitting motion papers; lead counsel must personally confer on disputes prior to involving the court.
  • Motions for extension of deadlines do not qualify as emergency motions.
  • +10 more

Request must include

Reason For RequestProposed New DatesProposed Rescheduled Date

Communication

Email

Clerk, Chambers

kellie_papaioannou@txs.uscourts.gov
SchedulingEmergenciesTechnical Issues
No status inquiries
Phone

Chambers

(361) 693-6403
No status inquiries
Letter via ECF

Chambers

SchedulingEmergenciesTechnical Issues
No status inquiries
Filters:AllMandatoryImportantFormattingDiscoveryExhibitsJPTOEvidence/WitnessesJuryLettersMemoranda

Page & Word Limits6 rules

Page Limits

Machine summary. Not checked yet.Mandatory?

Do not submit a reply letter.

Summary: Reply letters to pre-motion letters regarding discovery and scheduling disputes are prohibited.

Structured details unavailable. See the source text.

Form 3 Order for Scheduling Conference and Disclosure of Interested Parties (current) · p. 4
|Sec5. Pre-motion Conferences Required for Discovery and Other Pretrial Disputes
Page Limits

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The opposing party should promptly submit a responsive letter of similar length identifying any disagreement.

Summary: Opposing party must submit responsive pre-motion letter of up to 2 pages.

Letter

Form 3 Order for Scheduling Conference and Disclosure of Interested Parties (current) · p. 4
|Sec5. Pre-motion Conferences Required for Discovery and Other Pretrial Disputes
Page LimitsCivil cases

Machine summary. Not checked yet.Mandatory?

two pages. The opposing party should promptly submit a responsive letter of similar length identifying any disagreement.

Summary: Pre-motion and responsive letters are limited to 2 pages.

Letter

2 pages

Applies to: Attorney

Responsive Letter

2 pages

Applies to: Attorney

Page Limits

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Bring any request by letter not to exceed approximately three single-spaced pages.

Summary: Letters requesting in camera inspection of privilege logs are limited to approximately three single-spaced pages.

Letter

3 pages

Applies to: Attorney

dbt procedures · p. 10
|SecPRIVILEGE LOGS
Page Limits

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If the Court asks for supplemental briefing, limit it to ten pages.

Summary: Supplemental briefing requested by the Court is limited to ten pages.

Supplemental Brief

10 pages

Applies to: Attorney

dbt procedures · p. 13
|SecMotion practice and hearings
Page Limits

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If the Court asks for supplemental briefing, limit it to ten pages.

Summary: Supplemental briefing requested by the Court is limited to ten pages.

Supplemental Brief

10 pages

Applies to: Attorney

Document Format Requirements33 rules

Formatting

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Use Form 4 on this Court’s home page. 1

Summary: Proposed scheduling order must use Form 4 from the Court’s home page.

Formatting

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Use the forms provided on the Court’s website. https://www.txs.uscourts.gov/Tipton.

Summary: Joint Pretrial Orders must use the forms provided on the Court’s website.

FormattingCivil cases

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Use Form 4 on this Court’s home page.

Summary: Proposed scheduling order must use Form 4 from the Court’s home page.

FormattingCivil cases

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Use the forms provided on the Court’s website. https://www.txs.uscourts.gov/Tipton.

Summary: Joint Pretrial Orders must use the forms provided on the Court’s website and contain Rule 26(a)(3) disclosures.

Form 4 The JDCMP and Proposed Scheduling Order (current) · p. 6
|SecJOINT PRETRIAL ORDER AND MOTION IN LIMINE DEADLINE
Formatting

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Form. Provide hard copies as well as electronic copies. When providing hard copies, organize exhibits and attachments by tab at the right margin. Use the smallest binders that comfortably hold the material. Do not use binders larger than four inches. Divide into multiple binders when necessary. Provide courtesy copies marked with the file-stamped CM/ECF system docket number unless submitted on an urgent basis.

Summary: Courtesy copies must include hard and electronic copies, with hard copies tabbed, binder size limited to 4 inches, and marked with CM/ECF docket number unless urgent.

Layout & Binding
Binding Style
Tabbed Three Ring
dbt procedures · p. 5
|SecCourt copies
Formatting

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Use American letter-size paper, a minimum 12-point font, and a minimum of 1-inch margins with ½-inch margins for footnotes, page numbers and any headers or footers. Double space except for lengthy quotations, headings, and footnotes.

Summary: Motion papers must use letter-size paper, minimum 12-point font, 1-inch margins (½-inch for footnotes/headers), double spacing except for specified sections.

Typography
Size12 pt
Line SpacingDouble
Layout & Binding
Margins
Top:1"
Left:1"
Right:1"
Bottom:1"
dbt procedures · p. 12
|Sec16. BRIEFING REQUIREMENTS
Formatting

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Do not make copies. Return all questionnaires on conclusion of jury selection.

Summary: Juror questionnaires may not be copied and must be returned after jury selection concludes.

dbt procedures · p. 17
|Sec24. JURY SELECTION
Formatting

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Boilerplate objections or responses will not be considered.

Summary: Boilerplate objections or responses to deposition designations will not be considered by the Court.

dbt procedures · p. 17
|Sec22. Deposition designations
Formatting

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Do not file boilerplate motions.

Summary: Boilerplate motions in limine are prohibited.

dbt procedures · p. 17
|Sec23. MOTIONS IN LIMINE
Formatting

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Each side must provide supporting legal authority for all requested instructions, definitions, and questions.

Summary: Criminal parties must provide supporting legal authority for all requested jury instructions, definitions, and questions.

dbt procedures · p. 18
|Sec25. JURY INSTRUCTIONS
Formatting

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In civil cases, counsel for Plaintiff must also submit a Word version by email to the Court’s Case Manager. In criminal cases, counsel for Prosecution and Defense must each also submit a Word version by email.

Summary: Jury instruction court copies must be submitted in Word (DOCX) format.

Required Format

DOCX

dbt procedures · p. 18
|Sec25. JURY INSTRUCTIONS
Formatting

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Submit a complete joint charge with the proposed instructions in the order that you would like them read to the jury. Where the parties agree, say so in the heading of that proposed instruction. Where the parties disagree, each party should offer their own proposed instruction in order. Present each instruction, definition, and question with supporting legal authority; Use the Fifth Circuit Pattern Jury Instructions whenever possible; and Identify with legal support any deviations from the pattern instructions.

Summary: Civil joint proposed jury charges must meet specific content and formatting requirements including order, authority, and pattern instruction use.

dbt procedures · p. 18
|Sec25. JURY INSTRUCTIONS
Formatting

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Use black font for all agreed findings and conclusions. Make it clear in the proposed findings that this means that the parties are agreed as to those. Where the parties disagree, use different color font. For example, if the parties do not agree on finding of fact number 7, plaintiff should submit their proposed number 7 in red and the defendant should submit their proposed number 7 in blue. Also, where the parties do not agree, provide citations to specific testimony and evidence from trial.

Summary: Agreed findings use black font; conflicting parties use red (plaintiff) and blue (defendant) font, with trial citations required for disagreements.

dbt procedures · p. 19
|SecBENCH TRIALS
Formatting

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Form. Provide hard copies as well as electronic copies. When providing hard copies, organize exhibits and attachments by tab at the right margin. Use the smallest binders that comfortably hold the material. Do not use binders larger than four inches. Divide into multiple binders when necessary. Provide courtesy copies marked with the file-stamped CM/ECF system docket number unless submitted on an urgent basis.

Summary: Hard copy courtesy copies must be tabbed at the right margin, in binders no larger than 4 inches, marked with CM/ECF docket number unless urgent.

Layout & Binding
Binding Style
Tabbed Three Ring
Formatting

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Style. Use American letter-size paper, a minimum 12-point font, and a minimum of 1-inch margins with ½-inch margins for footnotes, page numbers and any headers or footers. Double space except for lengthy quotations, headings, and footnotes.

Summary: Motion papers must use letter-size paper, minimum 12-point font, 1-inch margins (½-inch for footnotes/headers/footers), double-spaced except for quotations/headings/footnotes.

Typography
Size12 pt
Line SpacingDouble
Layout & Binding
Margins
Top:1"
Left:1"
Right:1"
Bottom:1"
Formatting

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Supply affidavits, deposition testimony excerpts, and supporting documents as separate exhibits to the filing. Provide a cover sheet to identify and separate each exhibit and identify them clearly on the CM/ECF docket entry when filing, e.g., “Exhibit A Declaration of John Doe.”

Summary: Supporting evidence must be filed as separate exhibits with cover sheets and clearly identified on CM/ECF docket entries.

Formatting

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Supply all cases or other authority not readily available through Westlaw or Lexis-Nexis as an appendix to any filing. Provide a cover sheet to identify and separate each authority.

Summary: Legal authority not available on Westlaw or Lexis-Nexis must be filed as an appendix with a cover sheet.

Formatting

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Use Form 7 to prepare a trial exhibit list, which must be filed on the date the Joint Pretrial Order is filed.

Summary: Trial exhibit lists must use Form 7 and be filed on the Joint Pretrial Order filing date.

Formatting

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Use Form 6 to prepare a Joint Pretrial Order.

Summary: Joint Pretrial Orders must be prepared using Form 6.

Tipton Procedures (Current) 05-2025 · p. 14
|SecJOINT PRETRIAL ORDERS IN CIVIL CASES
Formatting

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Unless otherwise set by Court order, on the date the Joint Pretrial Order is filed each party must file: • An exhibit list as per Section 20; • A witness list as per Section 21; • Designation of deposition excerpts as per Section 22; • Motions in limine as per Section 23; • Proposed topics and questions for voir dire as per Section 24; • In jury trials, a proposed joint jury charge as per Section 25; and • In bench trials, proposed findings of fact and conclusions of law as per Section 26.

Summary: Each party must file required pretrial filings on the date the Joint Pretrial Order is filed.

Formatting

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When filing the Joint Pretrial Order on the CM/ECF system, file the pretrial filings set out in Section 19 as exhibits.

Summary: Section 19 pretrial filings must be filed as exhibits to the Joint Pretrial Order on CM/ECF.

Tipton Procedures (Current) 05-2025 · p. 14
|SecJOINT PRETRIAL ORDERS IN CIVIL CASES
Formatting

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Each offering party must mark its own exhibits with the party’s name, case number, and exhibit number.

Summary: Trial exhibits must be marked with the offering party’s name, case number, and exhibit number.

Formatting

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All lead counsel must sign the Joint Pretrial Order.

Summary: Joint Pretrial Orders must be signed by all lead counsel.

Tipton Procedures (Current) 05-2025 · p. 14
|SecJOINT PRETRIAL ORDERS IN CIVIL CASES
Formatting

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Use Form 9 to prepare deposition designations, which must be filed on the date the Joint Pretrial Order is filed.

Summary: Deposition designations must be prepared using Form 9 and filed on the Joint Pretrial Order filing date.

Tipton Procedures (Current) 05-2025 · p. 17
|SecDeposition designations and exhibits in civil cases
Formatting

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Do not make copies.

Summary: Parties are prohibited from making copies of juror questionnaires.

Formatting

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Use black font for all agreed findings and conclusions. Make it clear in the proposed findings that this means that the parties are agreed as to those.

Summary: Agreed proposed findings and conclusions must be in black font.

Formatting

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Where the parties disagree, use different color font. For example, if the parties do not agree on finding of fact number 7, plaintiff should submit their proposed number 7 in red and the defendant should submit their proposed number 7 in blue.

Summary: Disagreed proposed findings must be in red for plaintiff and blue for defendant.

Formatting

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Court copies. In civil cases, counsel for Plaintiff must also submit a Word version by email to the Court’s Case Manager. In criminal cases, counsel for Prosecution and Defense must each also submit a Word version by email.

Summary: Civil plaintiffs and criminal prosecution and defense must submit Word-format jury instructions via email to the Court’s Case Manager.

Required Format

DOCX

Formatting

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Provide pinpoint citation for all legal authority. Do the same for evidence. For instance, cite to page and line for depositions, to page and paragraph number for affidavits and pleadings, and to page and section number for contracts and similar materials. Use Bates numbers as the page reference where available.

Summary: Pinpoint citations are required for all legal authority and evidence, with specific formatting per document type, and Bates numbers where available.

Formatting

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The Court disfavors footnotes. The Court disregards evidence or argument raised only in footnotes.

Summary: The Court disfavors footnotes and disregards evidence or argument raised solely in footnotes.

Formatting

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Exhibit lists may not be amended or supplemented after this date unless by agreement.

Summary: Trial exhibit lists cannot be amended or supplemented after filing unless parties agree.

Formatting

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List only those exhibits intended in good faith for use during trial.

Summary: Only exhibits intended in good faith for trial may be listed on trial exhibit lists.

Document Filing Requirements115 rules

Filing RequirementsCivil cases

Checked against the court's document on Oct 4, 2026Mandatory

The witness list must identify each intended case-in-chief witness by name and address and briefly describe the subject and substance of the testimony.

List in separate paragraphs the names and addresses of witnesses that each party intends in good faith to call in its case-in-chief. Include a brief statement of the subject matter and substance of the testimony of each.

Document Type

Witness List

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Checked against the court's document on Oct 4, 2026Mandatory

Each party must separately file and attach a Form 7 list of expected exhibits to the Joint Pretrial Order.

Each party must file as a separate document and attach to this Joint Pretrial Order a list of all exhibits expected to be offered. Use Form 7 to prepare the trial exhibit list.

Document Type

Joint Pretrial Order

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Checked against the court's document on Oct 4, 2026Mandatory

Each party must separately file and attach intended deposition designations to the Joint Pretrial Order, prepared using Form 9 and Section 22 of the Court’s procedures.

Each party must also file as a separate document and attach to this Joint Pretrial Order any intended deposition designations. Prepare the designations as per Section 22 of the Court’s procedures. Use Form 9 to prepare the deposition designations.

Document Type

Joint Pretrial Order

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Checked against the court's document on Oct 4, 2026Mandatory

Each party must separately file and attach a Form 8 witness list to the Joint Pretrial Order, prepared under Section 21 of the Court’s procedures.

Each party must file as a separate document and attach to this Joint Pretrial Order a list of all witnesses. Use Form 8 to prepare the trial witness list. Prepare the list as per Section 21 of the Court’s procedures.

Document Type

Joint Pretrial Order

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Checked against the court's document on Oct 4, 2026Mandatory

For a jury trial, each party must separately file and attach any motion in limine, proposed prospective-juror topics and questions, and a proposed joint jury charge to the Joint Pretrial Order.

For any jury trial, each party must file as a separate document and attach to this Joint Pretrial Order the following additional attachments. • Any motion in limine as per Section 23 of the Court’s Procedures; • Proposed topics and questions for examination of prospective jurors as per Section 24 of the Court’s Procedures; and • A proposed joint jury charge as per Section 25 of the Court’s Procedures.

Document Type

Joint Pretrial Order

Specific requirements detailed in rule text.
Form 6 JPTO (current) 0 · p. 4
|SecAdditional required attachments
Filing RequirementsCivil cases

Checked against the court's document on Oct 4, 2026Mandatory

For a bench trial, each party must separately file and attach proposed findings of fact and conclusions of law to the Joint Pretrial Order under Section 26 of the Court’s procedures.

For any bench trial, each party must file as a separate document and attach to this Joint Pretrial Order the following additional attachment. • Proposed findings of facts and conclusions of law as per Section 26 of the Court’s Procedures.

Document Type

Joint Pretrial Order

Specific requirements detailed in rule text.
Form 6 JPTO (current) 0 · p. 4
|SecAdditional required attachments
Filing RequirementsCivil cases

Checked against the court's document on Oct 4, 2026Important

Each offering party must mark its exhibits with the party’s name, case number, and exhibit number.

Each offering party must mark its own exhibits. Include the party’s name, case number, and exhibit number on each exhibit.

Document Type

Exhibit

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Checked against the court's document on Oct 4, 2026Important

Exhibit lists may not be amended or supplemented after filing the Joint Pretrial Order without agreement.

Exhibit lists may not be amended or supplemented after the date the Joint Pretrial Order is filed unless by agreement.

Document Type

Exhibit List

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Checked against the court's document on Oct 4, 2026Important

Parties must not provide the Court with copies of all exhibits.

Do not provide copies of all exhibits to the Court.

Document Type

Exhibit

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Checked against the court's document on Oct 4, 2026Important

The witness-related filing must include the specified statement about notifying opposing counsel of additional witnesses, subject to the rebuttal and impeachment exception.

Include the following statement: “If any other witnesses will be called at the trial, their names, addresses, and the subject matter of their testimony will be reported to opposing counsel as soon as they are known. This restriction will not apply to rebuttal or impeachment witnesses, the necessity of whose testimony cannot reasonably be anticipated before trial.”

Document Type

Witness List

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Counsel and all unrepresented parties must also file with the Clerk, at least 15 days before the Scheduling Conference, a certificate listing all persons, associations, firms, partnerships, corporations, affiliates, parent corporations, or other entities, including any unincorporated entities such as LLCs or LLPs, that are financially interested in the outcome of this litigation. Underline the name of each corporation

Summary: Counsel and pro se parties must file a certificate of interested parties with the Clerk at least 15 days before the Scheduling Conference, listing all financially interested entities and underlining corporation names.

Document Type

Certificate

Specific requirements detailed in rule text.
Filing Requirements

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persons or entities financially interested in the outcome of the litigation are identified during this litigation, an amended certificate must be filed promptly with the Clerk. If an unincorporated entity is named as a party, the certificate must state the citizenship of every member of that entity.

Summary: Amended certificate of interested parties must be filed promptly if new interested parties are identified; unincorporated entity certificates must state all members' citizenship.

Document Type

Certificate

Specific requirements detailed in rule text.
Filing Requirements

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State where and when the parties held the meeting required by Rule 26(f).

Summary: Joint Discovery/Case Management Plan must state time and location of Rule 26(f) meeting.

Document Type

Joint Discovery Case Management Plan

Specific requirements detailed in rule text.
Filing Requirements

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Identify the counsel who attended for each party.

Summary: Joint Discovery/Case Management Plan must identify counsel who attended Rule 26(f) meeting for each party.

Document Type

Joint Discovery Case Management Plan

Specific requirements detailed in rule text.
Filing Requirements

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Any such party must also attach to this filing an affidavit or declaration establishing the citizenship of every member.

Summary: Unincorporated entity parties must attach affidavit or declaration of all members' citizenship to Joint Discovery/Case Management Plan.

Document Type

Joint Discovery Case Management Plan

Specific requirements detailed in rule text.
Filing Requirements

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Describe any class-action or collective-action issues. Provide the proposed definition of the class. Identify the basis for any opposition.

Summary: Joint Discovery/Case Management Plan must describe class/collective action issues, proposed class definition, and opposition basis.

Document Type

Joint Discovery Case Management Plan

Specific requirements detailed in rule text.
Filing Requirements

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List any unserved parties. State a date certain by which that party will be served.

Summary: Joint Discovery/Case Management Plan must list unserved parties and provide firm service date.

Document Type

Joint Discovery Case Management Plan

Specific requirements detailed in rule text.
Filing Requirements

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Briefly describe what this case is about. In addition, state the elements of each cause of action, defense, and counterclaim.

Summary: Joint Discovery/Case Management Plan must include general case description and elements of all claims, defenses, and counterclaims.

Document Type

Joint Discovery Case Management Plan

Specific requirements detailed in rule text.
Filing Requirements

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If the case involves an unincorporated entity as a party (such as an LLC, LLP, or partnership), state the citizenship of every member or partner.

Summary: Joint Discovery/Case Management Plan must state citizenship of all members/partners for unincorporated entity parties.

Document Type

Joint Discovery Case Management Plan

Specific requirements detailed in rule text.
Filing Requirements

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Specify the basis of federal jurisdiction. Identify any parties who disagree and the reasons.

Summary: Joint Discovery/Case Management Plan must specify federal jurisdiction basis and identify disagreeing parties with reasons.

Document Type

Joint Discovery Case Management Plan

Specific requirements detailed in rule text.
Filing Requirements

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List all related cases pending in any other state or federal court. Identify the court and case number. Describe how it relates to this case.

Summary: Joint Discovery/Case Management Plan must list all related state and federal cases with court, case number, and relationship details.

Document Type

Joint Discovery Case Management Plan

Specific requirements detailed in rule text.
Filing Requirements

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For jurisdiction based on diversity, identify any disagreement about the amount in controversy.

Summary: Joint Discovery/Case Management Plan must identify diversity jurisdiction disputes about amount in controversy.

Document Type

Joint Discovery Case Management Plan

Specific requirements detailed in rule text.
Filing Requirements

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State whether the parties considered conducting discovery in phases.

Summary: Joint Discovery/Case Management Plan must state whether phased discovery was considered.

Document Type

Joint Discovery Case Management Plan

Specific requirements detailed in rule text.
Filing Requirements

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Describe any issues about preservation of discoverable information.

Summary: Joint Discovery/Case Management Plan must describe discoverable information preservation issues.

Document Type

Joint Discovery Case Management Plan

Specific requirements detailed in rule text.
Filing Requirements

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Indicate the parties’ joint position on referral of this case for all purposes, including trial, to a Magistrate Judge.

Summary: Joint Discovery/Case Management Plan must state parties' joint position on Magistrate Judge referral for all purposes including trial.

Document Type

Joint Discovery Case Management Plan

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Describe any requested change to limitations set by the Federal Rules of Civil Procedure as to interrogatories, depositions, or other matters.

Summary: Joint Discovery/Case Management Plan must describe requested changes to FRCP discovery limitations.

Document Type

Joint Discovery Case Management Plan

Specific requirements detailed in rule text.
Filing Requirements

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State whether each party has completed its Rule 26(a) initial disclosures. If not, specify the date by which each party will do so.

Summary: Joint Discovery/Case Management Plan must state initial disclosure completion status and provide completion dates if incomplete.

Document Type

Joint Discovery Case Management Plan

Specific requirements detailed in rule text.
Filing Requirements

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Discuss the possibility for prompt, agreed resolution of the case at the Rule 26(f) meeting. State whether the parties are amenable to early mediation or other settlement attempt.

Summary: Joint Discovery/Case Management Plan must discuss settlement possibilities and amenability to early mediation or settlement.

Document Type

Joint Discovery Case Management Plan

Specific requirements detailed in rule text.
Filing Requirements

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Specify any discovery already underway or accomplished.

Summary: Joint Discovery/Case Management Plan must specify all completed or ongoing discovery.

Document Type

Joint Discovery Case Management Plan

Specific requirements detailed in rule text.
Filing Requirements

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seeking to add them, briefly explain why, and indicate a date by which to do so.

Summary: Joint Discovery/Case Management Plan must list parties to be added, explain reason, and provide date for addition.

Document Type

Joint Discovery Case Management Plan

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Certify that all parties have filed the Disclosure of Interested Persons as directed in the Order for Conference and Disclosure of Interested Persons.

Summary: Joint Discovery/Case Management Plan must include certification that all parties filed required Disclosure of Interested Persons.

Document Type

Joint Discovery Case Management Plan

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Identify any party that has made a jury demand and whether it was timely.

Summary: Joint Discovery/Case Management Plan must identify parties making jury demands and whether demands were timely.

Document Type

Joint Discovery Case Management Plan

Specific requirements detailed in rule text.

Filing & Service rules

Electronic Filing Rules

All parties must electronically file all documents through the CM/ECF system, following local administrative procedures.

E-filing required. All parties must file documents through the Case Management/Electronic Case Filing System pursuant to LR5.1 and CrLR49. All parties must also obtain and follow the Administrative Procedures for Electronic Filing in Civil and Criminal Cases from the website of the Southern District of Texas.

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Page 3 | ELECTRONIC FILING AND SERVICE

Applications for restraining orders or immediate relief must be e-filed via CM/ECF.

File any application for restraining orders or other immediate relief through the CM/ECF system.

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Page 4 | Ex parte applications in civil cases

Emergency motions must be e-filed via CM/ECF.

Emergency motions. File emergency motions on the CM/ECF system.

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Page 4 | Emergency motions

Do not file copies of letters or emails on CM/ECF; the Court will docket or direct filing as needed.

Do not file copies of letters or email on the CM/ECF system. The Court dockets or directs filing as determined advisable.

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Page 5 | Informal communication with the Court

Initial disclosures must not be filed with the court.

Do not file initial disclosures.

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Page 8 | INITIAL DISCLOSURES AND COMMENCEMENT OF DISCOVERY IN CIVIL CASES

Physical delivery of documents to the Court or Case Manager does not satisfy filing requirements.

Handing documents to the Court or Case Manager does not constitute filing.

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Page 20 | COURTROOM PROCEDURES AND CONDUCT

Filing Timing and Cure Windows

Provide the Court only copies of exhibits subject to objections, no later than seven calendar days after the Joint Pretrial Order is filed.

Instead, provide only copies of exhibits to which objections are lodged no later than seven calendar days after the Joint Pretrial Order is filed.

Checked against the court's document on Oct 4, 2026 · Civil cases

Page 3 | Exhibits

All exhibits must be exchanged no later than the filing date of the Joint Pretrial Order.

Exchange all exhibits no later than the date the Joint Pretrial Order is filed.

Checked against the court's document on Oct 4, 2026 · Civil cases

Page 3 | Exhibits

Exhibit objections must be filed within three business days after the Joint Pretrial Order is filed.

Objections to any exhibit shall be filed no later than three business days after the date the Joint Pretrial Order is filed.

Checked against the court's document on Oct 4, 2026 · Civil cases

Page 3 | Exhibits

Objections to deposition designations must be filed within three business days after the Joint Pretrial Order is filed.

Objections to any deposition designation shall be filed no later than three business days after the date the Joint Pretrial Order is filed.

Checked against the court's document on Oct 4, 2026 · Civil cases

Page 4 | Witnesses

Responses to exhibit objections must be filed within six business days after the Joint Pretrial Order is filed.

Responses to those objections shall be filed no later than six business days after the date the Joint Pretrial Order is filed.

Not confirmed. Read the court's wording below. · Civil cases

Page 3 | Exhibits

Removing parties must file certificate of service and required information within 10 days of removal, with possible summary remand for non-compliance.

The removing party must file the certificate of service and provide the additional information within ten days of removal. The Court may summarily remand for failure of compliance.

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Page 3 | Applicability and compliance

Letters requesting in camera inspection must be submitted at least 60 days before discovery closes or promptly upon subsequent discovery.

Submit any letter at least sixty days before the end of discovery or promptly upon

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Page 10 | PRIVILEGE LOGS

Each party must file required pretrial filings (exhibit list, witness list, etc.) on the date the Joint Pretrial Order is filed.

Unless otherwise set by Court order, on the date the Joint Pretrial Order is filed each party must file: • An exhibit list as per Section 20; • A witness list as per Section 21; • Designation of deposition excerpts as per Section 22; • Motions in limine as per Section 23; • Proposed topics and questions for voir dire as per Section 24; • In jury trials, a proposed joint jury charge as per Section 25; and • In bench trials, proposed findings of fact and conclusions of law as per Section 26.

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Page 14 | Required Pretrial Filings

Exhibit objections must be filed with authority no later than three business days after the Joint Pretrial Order is filed.

The Court supersedes time limits set in LR44.1, LR46, and CrLR55.2.B and requires filing of any objections with authority no later than three business days after the date the Joint Pretrial Order is filed.

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Page 15 | Depositions and exhibits in civil cases

Responses to exhibit objections must be filed no later than six business days after the Joint Pretrial Order is filed.

File any response to objections no later than six business days after the date the Joint Pretrial Order is filed.

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Page 15 | Depositions and exhibits in civil cases

Witness objections must be filed with authority no later than three business days after the Joint Pretrial Order is filed.

File any objections with authority no later than three business days after the date the Joint Pretrial Order is filed.

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Page 16 | 21. WITNESS LISTS

Objections to deposition designations must be filed within 3 business days after the Joint Pretrial Order is filed.

Objections to any deposition designation shall be filed no later than three business days after the date the Joint Pretrial Order is filed.

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Page 17 | 22. Deposition designations

Motions in limine must be filed on the same date as the Joint Pretrial Order.

File separate motions in limine with a matching proposed order on the same date the Joint Pretrial Order is filed.

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Page 17 | 23. MOTIONS IN LIMINE

Responses to contested motions in limine must be filed within 3 business days after the Joint Pretrial Order is filed.

File a response to any motion in limine that is contested no later than three business days after the date the Joint Pretrial Order is filed.

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Page 17 | 23. MOTIONS IN LIMINE

Responses to deposition designation objections must be filed within 6 business days after the Joint Pretrial Order is filed.

Responses to those objections shall be filed no later than six business days after the date the Joint Pretrial Order is filed.

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Page 17 | 22. Deposition designations

Criminal prosecution and defense must file jury instruction documents 3 working days before the Final Pretrial Conference.

The Prosecution must file a proposed jury charge based on the Fifth Circuit Pattern Jury Instructions and supported modifications. The Defense must file objections or its own supported modifications. These must be filed three working days before the Final Pretrial Conference.

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Page 18 | 25. JURY INSTRUCTIONS

Original documents offered must be filed as soon as practicable.

File all original documents as soon as practicable.

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Page 20 | COURTROOM PROCEDURES AND CONDUCT

Service and Proof of Service Rules

Plaintiff must serve the Court's standing procedures with the summons and complaint and file proof of service.

Service. Plaintiff must formally serve these procedures with the summons and complaint and file proof of service.

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Page 3 | Applicability and compliance

Filing via CM/ECF is sufficient service for represented parties; pro se parties must use formal service methods.

Service. For parties represented by counsel with CM/ECF credentials, filing through the CM/ECF system constitutes sufficient service on other parties. For other parties, provide formal service in compliance with applicable rules.

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Page 3 | ELECTRONIC FILING AND SERVICE

TRO/immediate relief applicants must attempt immediate informal service on opposing parties via mail/email.

In addition to service required by rule, the initiating party must in good faith attempt immediate informal service on the opposing party by any available means, including forwarding the application to the last-known mail and email addresses.

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Page 4 | Ex parte applications in civil cases

Serve all parties with a copy of any letter or email sent to the Court using the same delivery method.

Prior to or with delivery of any letter or email to the Court, use the same means to provide a copy to all other parties.

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Page 5 | Informal communication with the Court

Service of the complaint on defendants must be perfected within 90 days of filing to avoid dismissal for want of prosecution.

The Court may dismiss for want of prosecution any Defendant upon whom Plaintiff has not perfected service within ninety days after filing the complaint pursuant to Rule 4(m).

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Page 7 | Joint Discovery/Case Management Plan and Proposed Scheduling Order

Trial exhibits must be exchanged; civil parties must exchange by the Joint Pretrial Order filing date, criminal schedule set by Court.

Seek agreement on the form of exchange. Absent agreement, exchange well-organized USB drives or provide for similar electronic transfer or download. In civil cases, exchange all exhibits no later than the date the Joint Pretrial Order is filed. In criminal cases, the Court sets the schedule for disclosure of exhibits.

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Page 14 | Trial Exhibit Lists

In civil cases, plaintiff must notify parties of witness order two days before trial, and update daily during trial.

In civil cases, by 8:00 p.m. two days in advance of the first day of trial, Plaintiff must notify all other parties as to the order of witnesses expected during the first two days of trial. Once trial commences, the parties must update one another at the end of each trial day on the order of witnesses expected during the next two trial days.

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Page 16 | 21. WITNESS LISTS

Revised deposition designations must be provided to opposing counsel two days before intended use.

Provide revised designations to opposing counsel two days in advance of intended use.

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Page 17 | 22. Deposition designations

Courtesy Copy Requirements

Courtesy copies are required only for trial exhibits or deposition excerpts with objections, which must be highlighted.

Do not provide courtesy copies to the Court except for the following: • Trial Exhibits to which objections have been lodged; and • Trial Deposition excerpts when objections have been lodged. Highlight the objections and the questions/answers to which those objections are directed.

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Page 5 | Court copies

Electronic courtesy copies must be emailed to the Case Manager; hard copies mailed or hand-delivered with a transmittal letter.

Delivery. Electronic copies should be sent to the Court’s case manager via email. Hard copies should be mailed or hand-delivered to the attention of the Case Manager with a transmittal letter specifying the content.

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Page 5 | Court copies

Only copies of exhibits with objections must be provided to the Court within seven calendar days of the Joint Pretrial Order being filed.

Do not provide copies of all exhibits to the Court. Instead, provide only copies of exhibits to which objections are lodged no later than seven calendar days after the Joint Pretrial Order is filed.

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Page 15 | Depositions and exhibits in civil cases

Civil plaintiffs and criminal prosecution/defense must submit Word versions of jury instructions by email to the Case Manager.

Court copies. In civil cases, counsel for Plaintiff must also submit a Word version by email to the Court’s Case Manager. In criminal cases, counsel for Prosecution and Defense must each also submit a Word version by email.

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Page 18 | 25. JURY INSTRUCTIONS

Counsel must submit a Word version of proposed findings to the Case Manager by email, with requirements varying by case type.

Court copies. In civil cases, counsel for Plaintiff must also submit a Word version by email to the Case Manager. In criminal cases, counsel for Prosecution and Defense must each submit a Word version by email.

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Page 19 | BENCH TRIALS

Two copies of documents filed during or within seven days prior to trial must be ready for the Court.

Have ready for the Court two copies of documents filed during or within seven days prior to trial or hearing.

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Page 20 | COURTROOM PROCEDURES AND CONDUCT

For emergency motions, file via CM/ECF then email a copy to the Case Manager immediately; extension motions are not emergencies.

Emergency motions. File emergency motions on the CM/ECF system. Then send a copy by email directly to the Case Manager so that it quickly reaches the Court’s attention. Motions for extension of deadlines are not emergencies.

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Page 4 | Emergencies

Electronic courtesy copies must be emailed to the Case Manager; hard copies mailed or hand-delivered to the Case Manager with a transmittal letter.

Delivery. Electronic copies should be sent to the Court’s case manager via email. Hard copies should be mailed or hand-delivered to the attention of the Case Manager with a transmittal letter specifying the content.

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Page 5 | Court copies

Courtesy copies are required only for trial exhibits with objections and trial deposition excerpts with objections, with objections highlighted.

When required. Do not provide courtesy copies to the Court except for the following: • Trial Exhibits to which objections have been lodged; and • Trial Deposition excerpts when objections have been lodged. Highlight the objections and the questions/answers to which those objections are directed.

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Page 5 | Court copies

Only copies of exhibits to which objections are lodged must be provided to the Court within seven calendar days after the Joint Pretrial Order is filed.

Do not provide copies of all exhibits to the Court. Instead, provide only copies of exhibits to which objections are lodged no later than seven calendar days after the Joint Pretrial Order is filed.

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Page 15 | Exhibit Lists

Witness lists must be submitted per Section 19 and a copy furnished to the court reporter before trial.

Court copies. Follow Section 19 regarding submission of witness lists. Also furnish a copy to the court reporter before trial.

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Page 16 | 21. WITNESS LISTS

Two copies of documents filed during or within seven days prior to trial must be ready for the Court.

Have ready for the Court two copies of documents filed during or within seven days prior to trial or hearing.

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Page 20 | COURTROOM PROCEDURES AND CONDUCT

Sealing & Redaction Procedures

Sealing a pleading or brief requires a motion to seal filed on the public docket with a redacted version attached, and the unredacted material filed under seal.

Motion required to seal. A presumption exists as to public access to judicial records. The Court disfavors the filing of any pleading, brief, or supporting follows. Under seal, file the at-issue pleading, brief, or other material. On the public record, separately file a motion to seal. Prepare and attach to the motion a redacted version of the material suitable to and proposed for filing on the public docket. In the alternative, establish cause why redaction is not possible.

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Page 7 | PROTECTIVE ORDERS AND FILINGS UNDER SEAL

Sealing requires a motion to seal filed on public docket with redacted material; unredacted material filed under seal on ECF with SEALED designation and informative title.

Motion required to seal. A presumption exists as to public access to judicial records. The Court disfavors the filing of any pleading, brief, or supporting follows. Under seal, file the at-issue pleading, brief, or other material. On the public record, separately file a motion to seal. Prepare and attach to the motion a redacted version of the material suitable to and proposed for filing on the public docket. In the alternative, establish cause why redaction is not possible. Identify all under-seal filings on the CM/ECF system with an informative title and designation of SEALED. For example, Motion for Summary Judgment (SEALED). Absent permission, do not simply identify a document as SEALED DOCUMENT without explanation.

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Page 7 | PROTECTIVE ORDERS AND FILINGS UNDER SEAL

Motions to seal are disfavored; parties must follow Section 10 procedures for sealed filings.

Motions to seal. The Court disfavors but will consider filings under seal. Proceed as directed under Section 10.

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Page 11 | 15. MOTION PRACTICE AND HEARINGS

Filing Bundling Requirements

Section 19 pretrial filings must be filed as exhibits with the Joint Pretrial Order on CM/ECF.

When filing the Joint Pretrial Order on the CM/ECF system, file the pretrial filings set out in Section 19 as exhibits.

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Page 14 | Joint Pretrial Orders in Civil Cases

Pre-Motion Conference Requirements

Pre-motion letter (max 2 pages) required to seek permission to file discovery/scheduling dispute motions, must include specified content and copy all parties.

Do not bring a motion on discovery and scheduling disputes without permission. To obtain permission, the party seeking relief must submit a letter not exceeding two pages. Identify the nature of the dispute, outline the issues, and state the contested relief sought. Describe the conference between lead counsel and summarize the results. Send a copy to all counsel and unrepresented parties.

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Page 4 | 5. Pre-motion Conferences Required for Discovery and Other Pretrial Disputes

Lead counsel must personally confer on all discovery and scheduling disputes before involving the Court.

Lead counsel must personally confer on all discovery and scheduling disputes as a final attempt at resolution prior to involving the Court.

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Page 4 | 5. Pre-motion Conferences Required for Discovery and Other Pretrial Disputes

Discovery and scheduling motions require prior permission and lead counsel conference before filing.

Any party wishing to make a discovery or scheduling motion must obtain permission before the submission of motion papers. This includes any motion to compel, to quash, for protection, or for extension. Lead counsel must personally confer on all discovery and scheduling disputes as a final attempt at resolution prior to involving the

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Page 12 | 9. Additional orders relating to disclosures, discovery, or pretrial motions

Pre-motion letters are limited to 2 pages, must include specified content, require responsive letters of similar length, prohibit replies, and copies must be sent to all counsel and unrepresented parties.

two pages. Identify the nature of the dispute, outline the issues, and state the contested relief sought. Describe the conference between lead counsel and summarize the results. Send a copy to all counsel and unrepresented parties. The opposing party should promptly submit a responsive letter of similar length identifying any disagreement. Do not submit a reply letter. The foregoing letters should be sent by email to the Court’s case manager, Kellie Papaioannou at Kellie_Papaioannou@txs.uscourts.gov.

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Page 13 | 5. Pre-motion Conferences Required for Discovery and Other Pretrial Disputes

Discovery, scheduling, compel, quash, protection, and extension motions require court permission before submission; lead counsel must personally confer prior to involving the court.

Any party wishing to make a discovery or scheduling motion must obtain permission before the submission of motion papers. This includes any motion to compel, to quash, for protection, or for extension. Lead counsel must personally confer on all discovery and scheduling disputes as a final attempt at resolution prior to involving the Court.

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Page 6 | Additional orders relating to disclosures, discovery, or pretrial motions

Pre-motion letters are required (max 2 pages) with specific content; responsive letters of similar length due promptly, no reply letters allowed, and copies sent to all parties.

two pages. Identify the nature of the dispute, outline the issues, and state the contested relief sought. Describe the conference between lead counsel and summarize the results. Send a copy to all counsel and unrepresented parties. The opposing party should promptly submit a responsive letter of similar length identifying any disagreement. Do not submit a reply letter.

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Page 7

Ex parte restraining order applications will only be considered if the initiating party complies with Rule 65(b) requirements.

Ex parte applications in civil cases. The Court does not entertain ex parte applications for restraining orders unless the initiating party satisfies the requirements of Rule 65(b).

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Page 4 | Ex parte applications in civil cases

Pre-motion letter (max 2 single-spaced pages) required before filing discovery or scheduling dispute motions; responsive letters allowed, no replies.

Initiating letter required. Do not bring a motion on discovery or scheduling disputes without permission. To obtain permission, the party seeking relief must submit a letter not exceeding approximately two single-spaced pages. Identify the nature of the dispute, outline the issues, and state the contested relief sought. Specify the conference between lead counsel and summarize the results. The opposing party should promptly submit a responsive letter of similar length identifying any disagreement. Do not submit a reply letter.

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Page 10 | DISCOVERY AND SCHEDULING DISPUTES

Civil opposed motions: responses due 21 calendar days after motion filing; replies (if any) due 7 days after response; sur-replies prohibited without permission.

Opposed motions are submitted to the Court twenty-one calendar days from filing. The Court may rule on the motion at that time. Accordingly, file any response no later than twenty-one calendar days of the motion. There is no right to file a reply. The Court may consider a reply if it is filed prior to the Court ruling on the motion. Any reply must be filed no later than seven days after the response is filed. Do not file a sur-reply absent permission.

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Page 11 | 15. MOTION PRACTICE AND HEARINGS

Discovery or scheduling dispute motions may not be filed without prior permission under Section 13.c.

Do not bring a motion on discovery or scheduling disputes absent permission obtained under Section 13.c.

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Page 11 | 15. MOTION PRACTICE AND HEARINGS

Criminal case motion briefing follows CrLR12 and Federal Rule of Criminal Procedure 12.

Submission date and briefing deadline in criminal cases. The Court proceeds according to CrLR12 and Rule 12 of the Federal Rules of Criminal Procedure.

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Page 12 | 15. MOTION PRACTICE AND HEARINGS

Parties must confer in good faith on motions in limine to resolve undisputed issues before filing.

Confer in good faith so that only disputed motions remain for the Court to resolve.

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Page 17 | 23. MOTIONS IN LIMINE

Motions in limine are prohibited in bench trials.

Do not bring motions in limine in bench trials.

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Page 17 | 23. MOTIONS IN LIMINE

Motions in limine may not raise topics already resolved under Daubert or summary judgment.

Do not raise or re-urge topics resolved under Daubert or summary judgment practice.

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Page 17 | 23. MOTIONS IN LIMINE

Letter (max ~3 single-spaced pages) required to request in camera inspection of up to 20 privilege log documents, with lead counsel conferring beforehand.

In camera review available. When a party believes an opponent has misused its privilege log, it may request that the Court make in camera inspection of not more than twenty documents. Bring any request by letter not to exceed approximately three single-spaced pages. Lead counsel must confer in good faith to resolve the dispute prior to any letter. In the letter, identify the documents for review, state the grounds for challenge, specify the conference between lead counsel, and summarize the results. This letter establishes consent to ex parte contact between the Court and the party’s opponent regarding the nature and verity of the asserted privilege. Each party may freely submit only a single letter requesting in camera inspection. Submit any letter at least sixty days before the end of discovery or promptly upon

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Page 10 | PRIVILEGE LOGS

Pre-motion initiating letter (max ~2 single-spaced pages) required to obtain permission to file motions on discovery or scheduling disputes.

Initiating letter required. Do not bring a motion on discovery or scheduling disputes without permission. To obtain permission, the party seeking relief must submit a letter not exceeding approximately two single-spaced pages. Identify the nature of the dispute, outline the issues, and state the contested relief sought. Specify the conference between lead counsel and summarize the results. The opposing party should promptly submit a responsive letter of similar length identifying any disagreement. Do not submit a reply letter.

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Page 10 | DISCOVERY AND SCHEDULING DISPUTES

Civil motion responses due 21 calendar days after filing; replies due 7 days after response, no sur-replies without permission.

Submission date and briefing deadlines in civil cases. The Court follows the deadlines set forth in LR7.3. Opposed motions are submitted to the Court twenty-one calendar days from filing. The Court may rule on the motion at that time. Accordingly, file any response no later than twenty-one calendar days of the motion. There is no right to file a reply. The Court may consider a reply if it is filed prior to the Court ruling on the motion. Any reply must be filed no later than seven days after the response is filed. Do not file a sur-reply absent permission.

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Page 11 | 15. MOTION PRACTICE AND HEARINGS

Before filing Rule 12(b)(6) or 12(c) motions in civil cases, counsel must identify pleading issues and confer in good faith; certificate of conference must confirm this.

Motions to dismiss or for judgment on the pleadings in civil cases. Pleading deficiencies of a claim or counterclaim are often cured in whole or in part by a permissible amendment to the subject pleading. Before filing a motion to dismiss for failure to state a claim or counterclaim under Rule 12(b)(6), or a motion for judgment on the pleadings on a claim or counterclaim under Rule 12(c), identify such issues to the opposing party and confer in good faith to resolve them. The Court will strike motions that do not include this in the certificate of conference.

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Page 11 | 15. MOTION PRACTICE AND HEARINGS

Discovery or scheduling dispute motions may only be filed with prior permission under Section 13.c.

Motions on discovery and scheduling. Do not bring a motion on discovery or scheduling disputes absent permission obtained under Section 13.c.

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Page 11 | 15. MOTION PRACTICE AND HEARINGS

Parties must confer in good faith before filing motions in limine to resolve undisputed issues.

Confer in good faith so that only disputed motions in limine remain for the Court to resolve.

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Page 17 | Motions in limine

Court may resolve discovery/scheduling disputes via letters or telephonic/video conference, and set briefing schedule if motion is allowed.

The Court may dispose of the dispute on the letters. When determined advisable, the Court may schedule a telephonic or video conference as soon as practicable. The Court will dispose of disputes at the conference to the extent possible and establish the issues and briefing schedule of any written motion allowed.

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Page 4 | 5. Pre-motion Conferences Required for Discovery and Other Pretrial Disputes

Criminal motion briefing deadlines follow CrLR12 and Rule 12 of the Federal Rules of Criminal Procedure.

Submission date and briefing deadline in criminal cases. The Court proceeds according to CrLR12 and Rule 12 of the Federal Rules of Criminal Procedure.

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Page 12 | 15. MOTION PRACTICE AND HEARINGS

Adjournment & Extension Requirements

Motions to extend discovery deadlines must be filed sufficiently early to allow opposing counsel to respond before the original deadline.

Motions for extension of discovery must be filed far enough in advance of the deadline to enable opposing counsel to respond before the deadline.

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Page 5

Extension requests must obtain court permission before submitting motion papers; lead counsel must personally confer on disputes prior to involving the court.

Any party wishing to make a discovery or scheduling motion must obtain permission before the submission of motion papers. This includes any motion to compel, to quash, for protection, or for extension. Lead counsel must personally confer on all discovery and scheduling disputes as a final attempt at resolution prior to involving the Court.

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Page 6 | Additional orders relating to disclosures, discovery, or pretrial motions

Modifying scheduling orders requires a motion showing good cause; continuance agreements are not binding, and must include adjusted dates for all subsequent deadlines.

Approval required. The Court will modify the Scheduling Order only upon a motion establishing good cause. Agreements on continuance of deadlines do not bind the Court but are given due consideration. Requested changes must include recommended dates to adjust all deadlines following the first modification.

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Page 7 | CONTINUANCES

Agreed extensions of submission dates must be communicated via letter or email, with a proposed order maintaining other deadlines.

Advise by letter or email of any agreed extension of the submission date. Provide a proposed order for any agreed extension that maintains other deadlines set by the Court.

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Page 12 | 15. MOTION PRACTICE AND HEARINGS

Continuances for missing witnesses are only granted if the witness was subpoenaed and failed to appear.

The Court will not recess to permit counsel to call a missing witness unless a witness fails to appear on subpoena.

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Page 20 | COURTROOM PROCEDURES AND CONDUCT

Continuances for interpreter issues are only granted if a scheduled interpreter fails to appear.

The Court will not recess to permit counsel to obtain an interpreter unless a scheduled interpreter fails to appear.

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Page 20 | COURTROOM PROCEDURES AND CONDUCT

Modification of the Scheduling Order requires a motion establishing good cause.

The Court will modify the Scheduling Order only upon a motion establishing good cause.

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Page 7 | CONTINUANCES

Agreed extensions of motion submission dates must be communicated by letter or email with reasons and a proposed order maintaining other deadlines.

certain. Provide reasons justifying prompt attention. Advise by letter or email of any agreed extension of the submission date. Provide a proposed order for any agreed extension that maintains other deadlines set by the Court.

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Page 12 | 15. MOTION PRACTICE AND HEARINGS

Motions for extension of deadlines do not qualify as emergency motions.

Motions for extension of deadlines are not emergencies.

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Page 4 | Emergency motions

Plaintiff may request a reasonable continuance of the scheduling conference if service has not been perfected.

Plaintiff may request a reasonable continuance if it has not perfected service.

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Page 7 | Joint Discovery/Case Management Plan and Proposed Scheduling Order

The court accommodates vacation and family-related continuance requests if made well in advance of hearings or trials.

Vacation requests. The Court respects and seeks to accommodate vacation and family requests if made well in advance of a hearing or trial setting.

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Page 7 | CONTINUANCES

Agreed extensions of discovery deadlines require no approval if they do not affect the Scheduling Order or other court-set deadlines.

Parties may agree to extension of discovery deadlines without seeking approval when the extension does not affect the Scheduling Order or other deadlines set by the Court.

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Page 7 | CONTINUANCES

Vacation and family-related continuance requests are accommodated if submitted well in advance of the hearing or trial.

The Court respects and seeks to accommodate vacation and family requests if made well in advance of a hearing or trial setting.

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Page 7 | CONTINUANCES

Chambers Communication Rules

Pre-motion letters must be sent by email to the Court’s case manager Kellie Papaioannou at Kellie_Papaioannou@txs.uscourts.gov.

two pages. Identify the nature of the dispute, outline the issues, and state the contested relief sought. Describe the conference between lead counsel and summarize the results. Send a copy to all counsel and unrepresented parties. The opposing party should promptly submit a responsive letter of similar length identifying any disagreement. Do not submit a reply letter. The foregoing letters should be sent by email to the Court’s case manager, Kellie Papaioannou at Kellie_Papaioannou@txs.uscourts.gov.

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Page 13 | 5. Pre-motion Conferences Required for Discovery and Other Pretrial Disputes

Pre-motion letters must be emailed to the Court’s case manager at the provided email address.

The foregoing letters should be sent by email to the Court’s case manager, Kellie Papaioannou at Kellie_Papaioannou@txs.uscourts.gov.

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Emergency motions must be emailed directly to the Case Manager after e-filing.

Then send a copy by email directly to the Case Manager so that it quickly reaches the Court’s attention.

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Page 4 | Emergency motions

Counsel must immediately email chambers to notify of pending motion resolution before court ruling.

Immediately advise by email of resolution of a pending motion prior to the Court’s ruling.

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Page 12 | 15. MOTION PRACTICE AND HEARINGS

Parties must immediately notify the Court by email upon reaching a settlement in civil cases.

Immediately notify the Court by email of settlement.

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Page 22 | Mediation and settlements in civil cases

All inquiries regarding cases assigned to Judge Tipton must be directed to Case Manager Kellie Papaioannou via email.

Direct inquiries regarding any case assigned to Judge Tipton to: Kellie Papaioannou Case Manager to Judge Drew B. Tipton 515 Rusk Street, Room 5300 Houston, Texas 77002 (361) 693-6403 Email: Kellie_Papaioannou@txs.uscourts.gov

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Page 1 | Informal communication with the Court

Do not initiate contact with Law Clerks unless returning a message; only discuss the specific subject of their inquiry.

Law Clerks. A Law Clerk may contact counsel with a specific inquiry at the Court’s direction. Do not initiate contact with the Law Clerks unless returning a message. Do not discuss matters beyond the indicated subject.

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Page 5 | Informal communication with the Court

Counsel must immediately notify chambers via email of any motion resolution before the Court rules.

Resolution by agreement. Immediately advise by email of resolution of a pending motion prior to the Court’s ruling. The Court will then deny the motion as moot or have the clerk terminate the motion.

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Page 12 | 15. MOTION PRACTICE AND HEARINGS

Parties must notify the Court by letter or email when serious settlement discussions are underway.

Notify the Court by letter or email whenever serious settlement discussions are underway.

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Page 22 | 29. MEDIATION AND SETTLEMENTS IN CIVIL CASES

Parties must immediately notify the Court by email upon settlement.

Immediately notify the Court by email of settlement.

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Page 22 | 29. MEDIATION AND SETTLEMENTS IN CIVIL CASES

Do not initiate contact with Law Clerks unless returning a message; only discuss specified subjects.

Law Clerks. A Law Clerk may contact counsel with a specific inquiry at the Court’s direction. Do not initiate contact with the Law Clerks unless returning a message. Do not discuss matters beyond the indicated subject.

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Page 5 | Informal communication with the Court

Pre-motion letters regarding discovery and scheduling disputes must be emailed to the Court’s case manager.

The foregoing letters should be sent by email to the Court’s case manager, Kellie Papaioannou at Kellie_Papaioannou@txs.uscourts.gov.

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Page 4 | 5. Pre-motion Conferences Required for Discovery and Other Pretrial Disputes

Inquiries about cases assigned to Judge Tipton must be directed to Chambers Case Manager Kellie Papaioannou via email.

Direct inquiries regarding any case assigned to Judge Tipton to: Kellie Papaioannou Case Manager to Judge Drew B. Tipton 515 Rusk Street, Room 5300 Houston, Texas 77002 (361) 693-6403 Email: Kellie_Papaioannou@txs.uscourts.gov

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Page 1

All communications related to ex parte applications must be made through the Case Manager via email.

Communication. Make all related communications through the Case Manager via telephone or email.

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Page 4 | Ex parte applications in civil cases

The Court disfavors informal communication; substantive issues must be addressed via written filings or in-person hearings.

Informal communication disfavored. The Court disfavors informal communication about cases except as stated in these procedures. Do not address substantive issues in informal communication. Address such issues only through written filings and in-person conferences and hearings.

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Page 4 | INFORMAL COMMUNICATION WITH THE COURT

Court staff (Case Manager, Law Clerks, etc.) do not provide legal advice or predict case outcomes.

Neither the Case Manager, the Law Clerks, nor other personnel provide legal advice or predict what the Court will do on a given matter.

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Page 4 | INFORMAL COMMUNICATION WITH THE COURT

Contact the Court through the Case Manager using specified methods based on communication purpose.

the Court through the Case Manager. Unless stated otherwise below, use the following: • Letters to initiate discovery and scheduling disputes under Section 13; • Letters or email for other minor procedural questions; and • Email or telephone for matters requiring prompt attention.

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Page 5 | Informal communication with the Court

Check the District Court website and CM/ECF system for status updates before contacting the Court; direct filing questions to the Clerk.

Status inquiries. Seek answers when possible from the District Court’s website. Review information on the status of documents, entry of orders, and docket entries on the CM/ECF system prior to contacting the Court. Direct filing questions to the Office of the Clerk.

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Page 5 | Informal communication with the Court

Counsel may request oral argument via email, must include justification for the request.

Counsel may jointly or individually advise by email of any request for oral argument together with circumstances to justify it.

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Page 12 | 15. MOTION PRACTICE AND HEARINGS

Courtroom access outside normal hours must be arranged in advance via email with the Case Manager.

Arrange in advance by email with the Case Manager for any necessary access before or after normal hours.

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Page 20 | COURTROOM PROCEDURES AND CONDUCT

Contact the Court through the Case Manager using specified methods for different inquiry types.

the Court through the Case Manager. Unless stated otherwise below, use the following: • Letters to initiate discovery and scheduling disputes under Section 13; • Letters or email for other minor procedural questions; and • Email or telephone for matters requiring prompt attention.

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Page 5 | Informal communication with the Court

Check District Court website and CM/ECF for status updates before contacting the Court; direct filing questions to the Clerk.

Status inquiries. Seek answers when possible from the District Court’s website. Review information on the status of documents, entry of orders, and docket entries on the CM/ECF system prior to contacting the Court. Direct filing questions to the Office of the Clerk.

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Page 5 | Informal communication with the Court

All filing questions must be directed to the Office of the Clerk.

Direct filing questions to the Office of the Clerk.

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Page 5 | Informal communication with the Court

Counsel may request oral argument via email, providing justification; Court sets oral argument at its discretion.

Oral argument. Adequate motion papers are particularly important. The Court rules on most motions on the papers and sets oral argument when determined advisable. Counsel may jointly or individually advise by email of any request for oral argument together with circumstances to justify it.

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Page 12 | 15. MOTION PRACTICE AND HEARINGS

After-hours courtroom access must be arranged in advance via email with the Case Manager.

Courtroom access. Arrange in advance by email with the Case Manager for any necessary access before or after normal hours.

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Page 20 | COURTROOM PROCEDURES AND CONDUCT

About United States District Judge Drew B. Tipton

**United States District Judge Drew B. Tipton** was appointed to the Southern District of Texas by President Donald Trump in 2020. Born in Angleton, Texas, Judge Tipton served in the United States Marine Corps Reserve as a radio operator assigned to an infantry battalion. From 1995 to 2020, he maintained a private law practice focusing on complex labor and employment and theft of trade secret disputes. He now serves in the Corpus Christi and Victoria Divisions of the Southern District of Texas. **Education** - South Texas College of Law, J.D. - Texas A&M University, B.A. in History and Economics **Career** - United States District Judge, Southern District of Texas, Corpus Christi and Victoria Divisions (2020–present) - Private practice, complex labor and employment and trade secret disputes (1995–2020) - Law Clerk, The Honorable John D. Rainey, Southern District of Texas - United States Marine Corps Reserve (radio operator, infantry battalion)

**Division:** Corpus Christi / Victoria **Courthouse:** Bob Casey United States Courthouse, 515 Rusk Street, Room 11122, Courtroom 11C, Houston, Texas 77002 **Phone:** (713) 250-2707 **Chambers Staff** - Case Manager: Kellie Papaioannou, (361) 693-6403, kellie_papaioannou@txs.uscourts.gov - Law Clerk: Taylor Leger - Law Clerk: Stephen Privat - Law Clerk: Jack Tucker

Common questions about Judge Drew B. Tipton's rules

Are courtesy copies required for Judge Drew B. Tipton?

Courtesy-copy rule applies for trial exhibits and trial deposition excerpts. Details: delivery upon filing. Courtesy copies are required only for trial exhibits or deposition excerpts with objections, which must be highlighted.

View ruleSource: page 5, section Court copies

Does Judge Drew B. Tipton require a pre-motion conference or letter before filing a motion?

Judge Drew B. Tipton's rules set a pre-motion procedure for discovery and scheduling dispute. Lead counsel must personally confer on all discovery and scheduling disputes before involving the Court.

View ruleSource: page 4, section 5. Pre-motion Conferences Required for Discovery and Other Pretrial Disputes

What page or word limits apply to reply letter before Judge Drew B. Tipton?

Reply letters to pre-motion letters regarding discovery and scheduling disputes are prohibited.

View ruleSource: page 4, section 5. Pre-motion Conferences Required for Discovery and Other Pretrial Disputes

What page or word limits apply to letter before Judge Drew B. Tipton?

Judge Drew B. Tipton's rule states these limits: attorney: 2 pages; attorney: 2 pages. Pre-motion and responsive letters are limited to 2 pages.

View ruleSource: page 7

What formatting rules apply to filings before Judge Drew B. Tipton?

Judge Drew B. Tipton's formatting rule includes binding tabbed 3-ring, provide both hard and electronic copies, organize exhibits/attachments by tab at right margin, use smallest comfortable binders, max 4 inches, and mark with cm/ecf docket number unless urgent. Courtesy copies must include hard and electronic copies, with hard copies tabbed, binder size limited to 4 inches, and marked with CM/ECF docket number unless urgent.

View ruleSource: page 5, section Court copies

What must be included with certificate filings before Judge Drew B. Tipton?

The rule identifies required filing content or certificates. Counsel and pro se parties must file a certificate of interested parties with the Clerk at least 15 days before the Scheduling Conference, listing all financially interested entities and underlining corporation names.

View ruleSource: page 2, section 2. Disclosure of Interested Parties

What must be included with joint discovery case management plan filings before Judge Drew B. Tipton?

The rule identifies required filing content or certificates. Joint Discovery/Case Management Plan must state time and location of Rule 26(f) meeting.

View ruleSource: page 7, section 1. Rule 26(f) meeting.

How may parties contact Judge Drew B. Tipton's chambers?

The rule addresses email communications with Judge Drew B. Tipton's chambers. The rule lists email Kellie_Papaioannou@txs.uscourts.gov. Pre-motion letters must be sent by email to the Court’s case manager Kellie Papaioannou at Kellie_Papaioannou@txs.uscourts.gov.

View ruleSource: page 13, section 5. Pre-motion Conferences Required for Discovery and Other Pretrial Disputes

How does Judge Drew B. Tipton handle sealed or redacted filings?

A motion to seal is required for covered sealed filings before Judge Drew B. Tipton. Process: file redacted on ecf. Sealing a pleading or brief requires a motion to seal filed on the public docket with a redacted version attached, and the unredacted material filed under seal.

View ruleSource: page 7, section PROTECTIVE ORDERS AND FILINGS UNDER SEAL

How do I request an adjournment or extension before Judge Drew B. Tipton?

Advance notice is not fully stated in the structured details. Motions to extend discovery deadlines must be filed sufficiently early to allow opposing counsel to respond before the original deadline.

View ruleSource: page 5

Does Judge Drew B. Tipton require motion papers to be bundled?

Yes. Judge Drew B. Tipton requires bundling for covered papers. Section 19 pretrial filings must be filed as exhibits with the Joint Pretrial Order on CM/ECF.

View ruleSource: page 14, section Joint Pretrial Orders in Civil Cases

Is electronic filing required before Judge Drew B. Tipton?

Yes. Electronic filing is required for the covered filings. All parties must electronically file all documents through the CM/ECF system, following local administrative procedures.

View ruleSource: page 3, section ELECTRONIC FILING AND SERVICE

What filing deadlines does Judge Drew B. Tipton set?

Exhibit objections must be filed within three business days after the Joint Pretrial Order is filed.

View ruleSource: page 3, section Exhibits

What rule applies to serving the opposing party before Judge Drew B. Tipton?

Proof of service is required for the covered service rule. Details: recipient: the opposing party. Plaintiff must serve the Court's standing procedures with the summons and complaint and file proof of service.

View ruleSource: page 3, section Applicability and compliance
Complete rules summary for Judge Drew B. Tipton

Counsel and pro se parties must file a certificate of interested parties with the Clerk at least 15 days before the Scheduling Conference, listing all financially interested entities and underlining corporation names.

Amended certificate of interested parties must be filed promptly if new interested parties are identified; unincorporated entity certificates must state all members' citizenship.

Lead counsel must personally confer on all discovery and scheduling disputes before involving the Court.

Pre-motion letter (max 2 pages) required to seek permission to file discovery/scheduling dispute motions, must include specified content and copy all parties.

Reply letters to pre-motion letters regarding discovery and scheduling disputes are prohibited.

Pre-motion letters regarding discovery and scheduling disputes must be emailed to the Court’s case manager.

Court may resolve discovery/scheduling disputes via letters or telephonic/video conference, and set briefing schedule if motion is allowed.

Motions to extend discovery deadlines must be filed sufficiently early to allow opposing counsel to respond before the original deadline.

Joint Discovery/Case Management Plan must state time and location of Rule 26(f) meeting.

Joint Discovery/Case Management Plan must identify counsel who attended Rule 26(f) meeting for each party.

Joint Discovery/Case Management Plan must specify federal jurisdiction basis and identify disagreeing parties with reasons.

Joint Discovery/Case Management Plan must identify diversity jurisdiction disputes about amount in controversy.

Joint Discovery/Case Management Plan must state citizenship of all members/partners for unincorporated entity parties.

Unincorporated entity parties must attach affidavit or declaration of all members' citizenship to Joint Discovery/Case Management Plan.

Joint Discovery/Case Management Plan must include general case description and elements of all claims, defenses, and counterclaims.

Joint Discovery/Case Management Plan must list all related state and federal cases with court, case number, and relationship details.

Joint Discovery/Case Management Plan must describe class/collective action issues, proposed class definition, and opposition basis.

Joint Discovery/Case Management Plan must list unserved parties and provide firm service date.

Joint Discovery/Case Management Plan must list parties to be added, explain reason, and provide date for addition.

Joint Discovery/Case Management Plan must list and explain anticipated interventions.

Joint Discovery/Case Management Plan must include certification that all parties filed required Disclosure of Interested Persons.

Joint Discovery/Case Management Plan must state initial disclosure completion status and provide completion dates if incomplete.

Joint Discovery/Case Management Plan must state whether phased discovery was considered.

Joint Discovery/Case Management Plan must specify all completed or ongoing discovery.

Joint Discovery/Case Management Plan must describe requested changes to FRCP discovery limitations.

Joint Discovery/Case Management Plan must describe discoverable information preservation issues.

Joint Discovery/Case Management Plan must specify all existing discovery disputes.

Joint Discovery/Case Management Plan must state whether protective order will be requested and describe confidentiality issues.

Joint Discovery/Case Management Plan must state whether e-discovery order will be requested and describe ESI issues.

Joint Discovery/Case Management Plan must discuss settlement possibilities and amenability to early mediation or settlement.

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