Court Rules
Judge George C. Hanks Jr.
Judge

Judge George C. Hanks Jr.

Individual Rules, Standing Orders & Policies

Rules last changed:
Southern District of Texas

Limits & Logistics

Document Limits

Letter
2 pgs
Brief
25 pgs

Courtesy Copies

All filings

  • Upon Filing

Filings >= 50 pages

  • Hand Delivery • Promptly

Motion, Brief

  • Hand Delivery • Within 3 Days

Trial Notebook, Exhibits

  • 2 copies • At Least 4 Business Days Before Trial

Adjournments

  • Motions to extend Docket Control Order deadlines or cut-off dates are not classified as emergencies.
  • Continuances and extensions are granted only at the Court’s discretion; joint agreements are not binding, and continuances for discovery disputes are rarely approved.
  • Extensions require good cause; first unopposed pre-deadline extensions usually granted, second case-by-case, third disfavored; post-deadline motions comply with FRCP 6(b)(2).
  • +1 more

Request must include

Reason For RequestAdversary PositionOriginal DateNumber Of Previous RequestsAffects Other Dates

Communication

Email

Clerk

cm4147@txs.uscourts.gov
Scheduling
Phone

Clerk

(713) 250-5500
Status Inquiries
Phone

Chambers

No status inquiries
Email

Chambers

Emergencies
Filters:AllMandatoryImportantFormattingJuryJPTOMemorandaEvidence/WitnessesExhibitsTRO/InjunctionDiscovery

Page & Word Limits2 rules

Page Limits

Machine summary. Not checked yet.Mandatory?

The parties should file a joint letter that does not exceed 2 pages, outlining the issues.

Summary: Joint letters filed for discovery/scheduling dispute conferences must not exceed 2 pages.

Letter

2 pages

GCH Court Procedures · Jan 2022 · p. 9
|SecDISCOVERY AND SCHEDULING DISPUTES
Page Limits

Machine summary. Not checked yet.Mandatory?

Without leave of Court, any motion, brief, or memorandum shall be limited to 25 pages, 13-point type-font, double-spaced, with 1” margins.

Summary: Motions, briefs, and memoranda are limited to 25 pages, 13-point font, double-spaced, 1-inch margins without leave of court.

Brief

25 pages

GCH Court Procedures · Jan 2022 · p. 10
|SecMOTIONS AND MEMORANDA OF LAW

Document Format Requirements15 rules

FormattingCivil cases

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

Before producing documents under the Initial Discovery Protocols, the parties must meet and confer about the production format.

Prior to the production of documents by either Party to the other pursuant to the Initial Discovery Protocols, the Parties will meet and confer regarding the format (e.g. TIFF/text, searchable .pdf, Excel) for such production.

Protocols - FLSA (Edison) · p. 3
|SecPART II: DEFINITIONS AND INSTRUCTIONS
Formatting

Machine summary. Not checked yet.Mandatory?

Do not submit a proposed order that contains a bare signature block.

Summary: Proposed orders are prohibited from containing a bare signature block.

GCH Court Procedures · Jan 2022 · p. 7
|SecC. Requirements for All Motions
Formatting

Machine summary. Not checked yet.Mandatory?

Please append copies of cases and the relevant parts of authorities that are cited only if the authorities are not found in commonly used resources such as the United States Code, United States Supreme Court Reporter, Federal Reporters, Federal Rules Decisions, Federal Supplement, Southwestern Reporter Second or Third, or Vernon=s Revised Statutes and Codes Annotated. Unpublished authorities that are easily available on Westlaw or Lexis also do not need to be provided to the Court.

Summary: Append copies of cited authorities only if not in commonly used resources or easily accessible on Westlaw/Lexis.

GCH Court Procedures · Jan 2022 · p. 11
|SecB. Copies of Authorities and Other Material Cited
Formatting

Machine summary. Not checked yet.Mandatory?

Copies of supporting affidavits, deposition testimony excerpts, and other evidence relied upon in the motion, brief, or memorandum should be separately filed in one or more appendices.

Summary: Evidence relied on in motions/briefs/memoranda must be filed in separate appendices.

GCH Court Procedures · Jan 2022 · p. 11
|SecB. Copies of Authorities and Other Material Cited
Formatting

Machine summary. Not checked yet.Mandatory?

contain a proposed order setting forth the relief requested by the movant. Orders should be in the form used by the Court, and should not contain any document system codes or client/matter billing numbers.

Summary: Proposed orders must use the Court's form and exclude system codes and billing numbers.

GCH Court Procedures · Jan 2022 · p. 11
|SecMOTIONS AND MEMORANDA OF LAW
Formatting

Machine summary. Not checked yet.Mandatory?

If the plaintiff fails to file the Joint Pretrial Order, then the defendant is responsible for filing the defendant=s portions of the Proposed Pretrial Order in the Joint Pretrial Order format.

Summary: Defendants must file their Joint Pretrial Order portions in proper format if plaintiffs fail to file timely.

GCH Court Procedures · Jan 2022 · p. 12
|Sec9. REQUIRED PRETRIAL AND TRIAL MATERIALS
Formatting

Machine summary. Not checked yet.Mandatory?

Each disputed instruction, definition, or question should be set out in bold type, underlined or italics and identified as disputed.

Summary: Disputed jury charge items must be formatted in bold, underline, or italics.

GCH Court Procedures · Jan 2022 · p. 14
|SecREQUIRED PRETRIAL AND TRIAL MATERIALS
Formatting

Machine summary. Not checked yet.Mandatory?

d. Prior to the start of trial, the parties shall also submit the proposed charge electronically in Microsoft Word, by emailing it to the Case Manager.

Summary: Proposed jury charge must be submitted in Microsoft Word format via email to the Case Manager prior to trial.

Required Format

DOCX

GCH Court Procedures · Jan 2022 · p. 14
|SecREQUIRED PRETRIAL AND TRIAL MATERIALS
Formatting

Machine summary. Not checked yet.Mandatory?

a. Proposed Findings of Fact and email it to the Case Manager (electronically in Microsoft Word);

Summary: For non-jury trials, Proposed Findings of Fact must be filed in Microsoft Word format.

Required Format

DOCX

GCH Court Procedures · Jan 2022 · p. 14
|SecREQUIRED PRETRIAL AND TRIAL MATERIALS
Formatting

Machine summary. Not checked yet.Mandatory?

b. Proposed Conclusions of Law and email it to the Case Manager (electronically in Microsoft Word); and

Summary: For non-jury trials, Proposed Conclusions of Law must be filed in Microsoft Word format.

Required Format

DOCX

GCH Court Procedures · Jan 2022 · p. 14
|SecREQUIRED PRETRIAL AND TRIAL MATERIALS
Formatting

Machine summary. Not checked yet.Mandatory?

The offering party should mark its own exhibits prior to trial and include the party=s name, case number, and exhibit number on each exhibit to be offered. (Example: Smith Construction, 3:10-cv-0010, Ex. 1.)

Summary: Offering parties should mark exhibits pre-trial with party name, case number, and exhibit number.

GCH Court Procedures · Jan 2022 · p. 25
|SecWitnesses and Witness List
Formatting

Machine summary. Not checked yet.Mandatory?

Each requested instruction, definition, and interrogatory must be numbered and presented on a separate sheet of paper with the citation and authority upon which counsel rely.

Summary: Jury instructions must be numbered, on separate sheets, with citations and authority.

GCH Court Procedures · Jan 2022 · p. 26
|SecAdditional Required Attachments
Formatting

Machine summary. Not checked yet.Important?

Counsel should use a numbering system during the discovery process to allow for the orderly discussion of documents during the discovery and pretrial process.

Summary: Counsel must use a numbering system for documents during discovery and pretrial process.

GCH Court Procedures · Jan 2022 · p. 10
|SecDISCOVERY AND SCHEDULING DISPUTES
Formatting

Machine summary. Not checked yet.Note?

A form Joint Pretrial Order is attached. It should be followed, but may be adapted, within reason, to accommodate the size and nature of the case.

Summary: Joint Pretrial Orders should use the Court's attached form, with reasonable adaptations allowed.

GCH Court Procedures · Jan 2022 · p. 12
|Sec9. REQUIRED PRETRIAL AND TRIAL MATERIALS
Formatting

Machine summary. Not checked yet.Note?

Recorded depositions should be edited to remove “dead air”.

Summary: Recorded depositions should be edited to remove dead air.

GCH Court Procedures · Jan 2022 · p. 25
|SecWitnesses and Witness List

Document Filing Requirements43 rules

Filing RequirementsCivil cases

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

A responding party providing a partial or incomplete answer or production must state the reason it is incomplete.

If a partial or incomplete answer or production is provided, the responding party must state the reason that the answer or production is partial or incomplete.

Document Type

Discovery Response

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Mandatory?

All motions except motions pursuant to Federal Rules of Civil Procedure 56 must be accompanied by a separate proposed order.

Summary: All motions except those under FRCP 56 must be accompanied by a separate proposed order.

Document Type

Motion

Content & Formatting
Proposed Order
GCH Court Procedures · Jan 2022 · p. 7
|SecC. Requirements for All Motions
Filing Requirements

Machine summary. Not checked yet.Mandatory?

All motions must contain a certificate of conference stating that counsel and pro se parties have conferred regarding the substance of the relief requested, and stating whether the relief is opposed or denied. In circumstances where opposition remains uncertain, the party filing the motion must make at least two attempts to ascertain whether the relief is opposed, and must provide a certificate of conference stating the number of attempts made to contact the opposing party, the method of those attempts (i.e., fax, e-mail, telephone call, postal mail), the date and time of the attempts, and the results obtained thereby. Even motions that may be unopposed, joint, or agreed by two or more parties require a certificate of conference.

Summary: All motions must include a certificate of conference detailing conferring efforts, opposition status, and contact attempts if opposition is uncertain.

Document Type

Motion

Content & Formatting
Certificate Of Conference
GCH Court Procedures · Jan 2022 · p. 7
|SecC. Requirements for All Motions
Filing Requirements

Machine summary. Not checked yet.Mandatory?

All pleadings or other documents filed under seal in a civil case must be identified as SEALED and by the title of the document. For example, a motion for summary judgment filed under seal must be docketed as “MOTION for Summary Judgment (SEALED).” No pleading may be filed for docketing simply as “SEALED DOCUMENT” without advance permission of the Court.

Summary: Sealed documents in civil cases must be labeled with SEALED and the document title; docketing as solely 'SEALED DOCUMENT' requires court permission.

Document Type

Sealed Document

Specific requirements detailed in rule text.
GCH Court Procedures · Jan 2022 · p. 8
|SecC. Requirements for All Motions
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Any motion, brief, or memorandum that has more than ten (10) pages of argument must contain the following items, while all motions, briefs and memoranda must contain items 3, 4, 6, and 7 below. 1. A table of contents with the page number of each section, including all headings designated in the body. 2. A short statement of the nature and stage of the proceeding. 3. A statement of the issues to be ruled upon by the Court and, with respect to each issue, a short statement (supported by legal authority) of the standard of review. 4. A short summary of the argument. 5. Succinct headings dividing the argument into separate points. 6. A short conclusion stating the precise relief sought.

Summary: All motions/briefs/memoranda must include specific sections; those with over 10 pages of argument require additional sections.

Document Type

Brief

Content & Formatting
Legal Argument
Table Of Contents
GCH Court Procedures · Jan 2022 · p. 10
|SecMOTIONS AND MEMORANDA OF LAW
Filing Requirements

Machine summary. Not checked yet.Mandatory?

All appendices should contain a table of contents, and courtesy copies of appendices or those filed conventionally (i.e., not electronically) should be tabbed at the right margin to facilitate location of the materials cited.

Summary: All appendices must include a table of contents.

Document Type

Appendices

Content & Formatting
Table Of Contents
GCH Court Procedures · Jan 2022 · p. 11
|SecB. Copies of Authorities and Other Material Cited
Filing Requirements

Machine summary. Not checked yet.Mandatory?

contain a proposed order setting forth the relief requested by the movant. Orders should be in the form used by the Court, and should not contain any document system codes or client/matter billing numbers.

Summary: Motions must include a proposed order detailing requested relief.

Document Type

Motion

Content & Formatting
Proposed Order
GCH Court Procedures · Jan 2022 · p. 11
|SecMOTIONS AND MEMORANDA OF LAW
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Joint Pretrial Orders must be signed by all counsel.

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

Document Type

Joint Pretrial Order

Specific requirements detailed in rule text.
GCH Court Procedures · Jan 2022 · p. 12
|Sec9. REQUIRED PRETRIAL AND TRIAL MATERIALS
Filing Requirements

Machine summary. Not checked yet.Mandatory?

c. Designations of deposition excerpts for witnesses being called by deposition. A copy of each deposition except must be provided to the Court.

Summary: Deposition designations for witnesses called by deposition must be filed, with copies of each deposition provided to the Court, for all trials and evidentiary hearings.

Document Type

Deposition Designation

Specific requirements detailed in rule text.
GCH Court Procedures · Jan 2022 · p. 13
|SecREQUIRED PRETRIAL AND TRIAL MATERIALS
Filing Requirements

Machine summary. Not checked yet.Mandatory?

e. Joint Trial Worksheet

Summary: Joint Trial Worksheet must be filed for all trials and evidentiary hearings.

Document Type

Joint Trial Worksheet

Specific requirements detailed in rule text.
GCH Court Procedures · Jan 2022 · p. 13
|SecREQUIRED PRETRIAL AND TRIAL MATERIALS
Filing Requirements

Machine summary. Not checked yet.Mandatory?

a. Each requested instruction must be numbered and presented with authority.

Summary: Each requested jury instruction must be numbered and presented with supporting authority.

Document Type

Proposed Jury Charge

Specific requirements detailed in rule text.
GCH Court Procedures · Jan 2022 · p. 13
|SecREQUIRED PRETRIAL AND TRIAL MATERIALS
Filing Requirements

Machine summary. Not checked yet.Mandatory?

a. Exhibit List (see attached form)

Summary: Exhibit List must be filed for all trials and evidentiary hearings.

Document Type

Exhibit List

Specific requirements detailed in rule text.
GCH Court Procedures · Jan 2022 · p. 13
|SecREQUIRED PRETRIAL AND TRIAL MATERIALS
Filing Requirements

Machine summary. Not checked yet.Mandatory?

d. Objections, if any, to an opponent=s exhibits. Objections must be filed within the time limits set out by the Local Rules.

Summary: Objections to opponent's exhibits must be filed within Local Rule time limits for all trials and evidentiary hearings.

Document Type

Objections To Exhibits

Specific requirements detailed in rule text.
GCH Court Procedures · Jan 2022 · p. 13
|SecREQUIRED PRETRIAL AND TRIAL MATERIALS
Filing Requirements

Machine summary. Not checked yet.Mandatory?

b. Witness List

Summary: Witness List must be filed for all trials and evidentiary hearings.

Document Type

Witness List

Specific requirements detailed in rule text.
GCH Court Procedures · Jan 2022 · p. 13
|SecREQUIRED PRETRIAL AND TRIAL MATERIALS
Filing Requirements

Machine summary. Not checked yet.Mandatory?

b. The parties shall include in the proposed jury charge all necessary instructions or definitions. The instructions shall, at a minimum, include: (1) the prima facie elements of each cause of action and defense asserted, (2) legal definitions required by the jury, (3) items of damages, and (4) methods of calculation of damages. Counsel are to use the appropriate state law Patterns, or the Fifth Circuit Pattern Jury Instructions, as modified by case law or statutory amendments, whenever possible. Any deviations must be identified, and accompanied with legal authorities for the proposed deviation.

Summary: Proposed jury charge must include minimum required instructions, use pattern jury instructions where possible, and deviations must be identified with legal authority.

Document Type

Proposed Jury Charge

Specific requirements detailed in rule text.
GCH Court Procedures · Jan 2022 · p. 13
|SecREQUIRED PRETRIAL AND TRIAL MATERIALS
Filing Requirements

Machine summary. Not checked yet.Mandatory?

2. For Jury Trials, the parties must file a single, joint proposed jury charge, including all necessary instructions, definitions and questions.

Summary: For jury trials, parties must file a single joint proposed jury charge including all necessary instructions, definitions, and questions.

Document Type

Proposed Jury Charge

Specific requirements detailed in rule text.
GCH Court Procedures · Jan 2022 · p. 13
|SecREQUIRED PRETRIAL AND TRIAL MATERIALS
Filing Requirements

Machine summary. Not checked yet.Mandatory?

e. The parties shall file a trial memorandum of law addressing the law governing the case and all contested issues.

Summary: For jury trials, parties must file a trial memorandum of law addressing applicable law and all contested issues.

Document Type

Trial Memorandum Of Law

Specific requirements detailed in rule text.
GCH Court Procedures · Jan 2022 · p. 14
|SecREQUIRED PRETRIAL AND TRIAL MATERIALS
Filing Requirements

Machine summary. Not checked yet.Mandatory?

b. Proposed Conclusions of Law and email it to the Case Manager (electronically in Microsoft Word); and

Summary: For non-jury trials, Proposed Conclusions of Law must be emailed to the Case Manager in Microsoft Word format.

Document Type

Proposed Conclusions Of Law

Specific requirements detailed in rule text.
GCH Court Procedures · Jan 2022 · p. 14
|SecREQUIRED PRETRIAL AND TRIAL MATERIALS
Filing Requirements

Machine summary. Not checked yet.Mandatory?

a. Proposed Findings of Fact and email it to the Case Manager (electronically in Microsoft Word);

Summary: For non-jury trials, Proposed Findings of Fact must be emailed to the Case Manager in Microsoft Word format.

Document Type

Proposed Findings Of Fact

Specific requirements detailed in rule text.
GCH Court Procedures · Jan 2022 · p. 14
|SecREQUIRED PRETRIAL AND TRIAL MATERIALS
Filing Requirements

Machine summary. Not checked yet.Mandatory?

c. Memorandum of Law. The memorandum of law, proposed findings, and proposed conclusions at a minimum should address the following: (1) the prima facie elements of each cause of action and defense asserted, (2) legal definitions, (3) components of damages, and (4) methods of calculation of damages.

Summary: For non-jury trials, memoranda of law, proposed findings, and proposed conclusions must address minimum required content including prima facie elements, legal definitions, damages components, and calculation methods.

Document Type

Memorandum Of Law

Specific requirements detailed in rule text.
GCH Court Procedures · Jan 2022 · p. 14
|SecREQUIRED PRETRIAL AND TRIAL MATERIALS
Filing Requirements

Machine summary. Not checked yet.Mandatory?

If parties cannot agree on instructions, definitions, or questions, the parties should nonetheless submit a single, unified charge. Each disputed instruction, definition, or question should be set out in bold type, underlined or italics and identified as disputed. Each disputed item should be labelled to show which party is requesting the disputed language. Accompanying each instruction shall be all authority or related materials upon which each party relies.

Summary: If parties disagree on jury charge items, submit unified charge with disputed items labeled, formatted in bold/underline/italics, and accompanied by authority.

Document Type

Proposed Jury Charge

Specific requirements detailed in rule text.
GCH Court Procedures · Jan 2022 · p. 14
|SecREQUIRED PRETRIAL AND TRIAL MATERIALS
Filing Requirements

Machine summary. Not checked yet.Mandatory?

The Trial Notebook should be submitted jointly, and must contain the Joint Pretrial Order as well as each side’s Exhibit Lists, Witness Lists, Designations, Objections, Motions in Limine, Jury Charges (where applicable), Memoranda of Law, and Proposed Findings of Fact and Conclusions of Law (where applicable).

Summary: Joint Trial Notebook must contain specified documents including Joint Pretrial Order, Exhibit Lists, Witness Lists, and others.

Document Type

Trial Notebook

Specific requirements detailed in rule text.
GCH Court Procedures · Jan 2022 · p. 14
|SecREQUIRED PRETRIAL AND TRIAL MATERIALS
Filing Requirements

Machine summary. Not checked yet.Mandatory?

The offering party shall mark its name, the case number, and the exhibit number on each exhibit to be offered.

Summary: Offering parties must mark their name, case number, and exhibit number on each exhibit they offer in civil cases.

Document Type

Exhibit

Content & Formatting
Case Number
Filing Requirements

Machine summary. Not checked yet.Mandatory?

List the parties, their respective counsel, and the mailing addresses, email addresses, and telephone numbers of counsel in separate paragraphs.

Summary: Joint Pretrial Order must include Appearance of Counsel section listing parties, counsel, and contact info in separate paragraphs.

Document Type

Joint Pretrial Order

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Give a brief agreed statement of the case for the information of the Court. The Court may read this statement to the jury panel to see whether any member of the panel is acquainted with the facts or parties in the case. Include names, dates and places.

Summary: Joint Pretrial Order must include agreed statement of the case with names, dates, and places.

Document Type

Joint Pretrial Order

Content & Formatting
Statement Of Facts
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Briefly explain why this Court has full and complete jurisdiction over the subject matter and the parties in this case. If there is an unresolved jurisdictional question, state the problem.

Summary: Joint Pretrial Order must include jurisdiction explanation and note any unresolved jurisdictional issues.

Document Type

Joint Pretrial Order

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Mandatory?

List all facts that have been stipulated to.

Summary: Joint Pretrial Order must list all stipulated facts.

Document Type

Joint Pretrial Order

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Delineate those legal propositions not in dispute.

Summary: Joint Pretrial Order must list undisputed legal propositions.

Document Type

Joint Pretrial Order

Specific requirements detailed in rule text.
GCH Court Procedures · Jan 2022 · p. 24
|SecAgreed Applicable Propositions of Law
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Identify any pending motions, as well as the responses, replies, or objections.

Summary: Joint Pretrial Order must identify pending motions and related responses, replies, and objections.

Document Type

Joint Pretrial Order

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Briefly state the issues of law in dispute.

Summary: Joint Pretrial Order must briefly state contested legal issues.

Document Type

Joint Pretrial Order

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Mandatory?

List all factual disputes that are necessary to the final disposition of this case.

Summary: Joint Pretrial Order must list all material factual disputes.

Document Type

Joint Pretrial Order

Content & Formatting
Statement Of Facts
GCH Court Procedures · Jan 2022 · p. 24
|SecContested Issues of Fact
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Along with this Joint Pretrial Order, each party or side should submit a memorandum of law to address these issues in more depth.

Summary: Memorandum of law addressing contested legal issues must be submitted with Joint Pretrial Order.

Document Type

Joint Pretrial Order

Content & Formatting
Legal Argument
Filing Requirements

Machine summary. Not checked yet.Mandatory?

The Exhibit List should provide a clear, concise description of each exhibit, with a Bates number from the discovery process where applicable.

Summary: Exhibit List must include clear description and Bates number for each exhibit.

Document Type

Exhibit List

Specific requirements detailed in rule text.
GCH Court Procedures · Jan 2022 · p. 24
|SecExhibits and Exhibit List
Filing Requirements

Machine summary. Not checked yet.Mandatory?

In separate paragraphs, give a concise statement of each party’s contentions and claims.

Summary: Joint Pretrial Order must include separate paragraphs stating each party's contentions and claims.

Document Type

Joint Pretrial Order

Specific requirements detailed in rule text.
GCH Court Procedures · Jan 2022 · p. 24
|SecContentions of the Parties
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Each party must attach an Exhibit List (in the form shown by Attachment A or a similar form) of all exhibits offered, and all parties must provide copies of their listed exhibits to opposing counsel in advance of trial.

Summary: Joint Pretrial Order must include Exhibit List of all offered exhibits in form of Attachment A or similar.

Document Type

Joint Pretrial Order

Content & Formatting
Exhibit List
GCH Court Procedures · Jan 2022 · p. 24
|SecExhibits and Exhibit List
Filing Requirements

Machine summary. Not checked yet.Mandatory?

If a witness is to appear by deposition, cite the inclusive pages and lines to be read or submitted.

Summary: Deposition witnesses require inclusive page and line citations for testimony to be read or submitted.

Document Type

Deposition Witness List

Specific requirements detailed in rule text.
GCH Court Procedures · Jan 2022 · p. 25
|SecWitnesses and Witness List
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Include a statement addressing whether or not all settlement efforts have been exhausted, the current settlement demand and offer, and whether the case can reasonably be expected to settle.

Summary: Settlement statements must include exhaustion of efforts, current demand/offer, and settlement likelihood.

Document Type

Settlement Statement

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Mandatory?

In the event there are any other witnesses to be called at the trial, their names, addresses and the subject matter of their testimony must be reported to opposing counsel as soon as they are known. This restriction shall not apply to a purely rebuttal or impeaching witness if necessity of the witness or the testimony cannot reasonably be anticipated before trial.

Summary: Additional trial witnesses must be reported to opposing counsel ASAP, with exemption for unforeseeable rebuttal/impeachment witnesses.

Document Type

Witness List

Specific requirements detailed in rule text.
GCH Court Procedures · Jan 2022 · p. 25
|SecWitnesses and Witness List
Filing Requirements

Machine summary. Not checked yet.Mandatory?

List the names and addresses of witnesses who will or may be called, and include a brief statement of the subject matter and substance of their testimony, as required by Fed. R. Civ. P. 26(a)(3).

Summary: Witness lists must include witness names, addresses, and subject matter of testimony per Fed. R. Civ. P. 26(a)(3).

Document Type

Witness List

Specific requirements detailed in rule text.
GCH Court Procedures · Jan 2022 · p. 25
|SecWitnesses and Witness List
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Include in this paragraph the following: (a) Whether trial will be Jury or Non-Jury; (b) Probable length of trial; and (c) Availability of witnesses.

Summary: Settlement statements must include trial type, probable length, and witness availability.

Document Type

Settlement Statement

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Mandatory?

For Jury Trials include the following: (a) Proposed questions for the venire panel. (b) Proposed jury instructions, definitions, and interrogatories. Each requested instruction, definition, and interrogatory must be numbered and presented on a separate sheet of paper with the citation and authority upon which counsel rely. (c) Memorandum of Law.

Summary: Jury trials require proposed venire questions, jury instructions (numbered, separate sheet, citations), and memorandum of law.

Document Type

Jury Trial Attachments

Specific requirements detailed in rule text.
GCH Court Procedures · Jan 2022 · p. 26
|SecAdditional Required Attachments
Filing Requirements

Machine summary. Not checked yet.Mandatory?

For Non-Jury Trials include the following: (a) Proposed Findings of Fact. (b) Proposed Conclusions of Law. (c) Memorandum of Law.

Summary: Non-jury trials require proposed findings of fact, conclusions of law, and memorandum of law.

Document Type

Non Jury Trial Attachments

Specific requirements detailed in rule text.
GCH Court Procedures · Jan 2022 · p. 26
|SecAdditional Required Attachments
Filing Requirements

Machine summary. Not checked yet.Note?

The Court discourages “catch-all” motions in limine. Instead, motions in limine should be directed to specific issues in the case and should relate to relief that is actually opposed.

Summary: Motions in limine should be specific to case issues and relate to opposed relief, not catch-all.

Document Type

Motion In Limine

Specific requirements detailed in rule text.
GCH Court Procedures · Jan 2022 · p. 26
|SecAdditional Required Attachments

Filing & Service rules

Filing Timing and Cure Windows

The Insurer must provide its Initial Discovery responses within 45 days after submitting a responsive pleading or motion, unless the court orders otherwise.

The Insurer’s Initial Discovery responses must be provided within 45 days after the Insurer has submitted a responsive pleading or motion, unless the court rules otherwise.

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

Page 7 | PART III: INFORMATION AND DOCUMENTS TO BE PRODUCED BY THE INSURER

Courtesy Copy Requirements

Fax or email delivery of documents to Chambers is prohibited unless the Court provides specific authorization.

Do NOT fax or email copies of documents to Chambers unless specifically authorized to do so by the Court.

Machine summary. Not checked yet.

Page 4 | COURTESY COPIES OF CERTAIN DOCUMENTS REQUIRED

Courtesy copies of documents 50 or more pages (including exhibits and attachments) must be promptly delivered to the Houston Clerk’s Office.

documents fifty (50) pages or more in length (including exhibits and attachments)

Machine summary. Not checked yet.

Page 4 | COURTESY COPIES OF CERTAIN DOCUMENTS REQUIRED

Courtesy copies of documents for matters being heard by the Court must be delivered to the Houston Clerk’s Office within three days of filing.

documents pertaining to matters being heard by the Court within three days after the document is filed

Machine summary. Not checked yet.

Page 4 | COURTESY COPIES OF CERTAIN DOCUMENTS REQUIRED

Two copies of the Joint Trial Notebook and each party’s exhibits must be submitted to the Court at least 4 business days before the first day of trial.

The Court requires 2 copies of a Joint Trial Notebook and each party’s exhibits be submitted to the Court at least 4 business days prior to the first day of trial.

Machine summary. Not checked yet.

Page 14 | REQUIRED PRETRIAL AND TRIAL MATERIALS

Sealing & Redaction Procedures

Designated Material filed with the Court is public unless a party moves to file it under seal, and this Order does not automatically seal it.

Any Designated Material which becomes part of an official judicial proceeding or which is filed with the Court is public. Such Designated Material will be sealed by the Court only upon motion and in accordance with applicable law. This Protective Order does not provide for the automatic sealing of such Designated Material. If it becomes necessary to file Designated Material with the Court, a party must move to file the Designated Material under seal.

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

Page 3 | 14

Filing Bundling Requirements

Joint Trial Notebook must be submitted jointly; if counsel cannot cooperate, each side submits its own notebook and exhibits.

The Trial Notebook should be submitted jointly, and must contain the Joint Pretrial Order as well as each side’s Exhibit Lists, Witness Lists, Designations, Objections, Motions in Limine, Jury Charges (where applicable), Memoranda of Law, and Proposed Findings of Fact and Conclusions of Law (where applicable). If counsel are wholly unable to cooperate, then each side is responsible for ensuring that its own Trial Notebook and exhibit binders are submitted.

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Page 14 | REQUIRED PRETRIAL AND TRIAL MATERIALS

All motions in limine must be filed with the pretrial order.

All Motions in Limine must be filed along with the Pretrial Order.

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Page 26 | Additional Required Attachments

Separate memoranda of law are prohibited; motions must include legal argument and authorities.

Generally, a motion should contain the legal argument and authorities and separate memoranda should not be filed.

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Page 10 | MOTIONS AND MEMORANDA OF LAW

Joint Exhibit List is encouraged where possible.

When possible, a Joint Exhibit List is preferred.

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Page 24 | Exhibits and Exhibit List

Pre-Motion Conference Requirements

Pre-motion conference required before filing specified motions (except in habeas, prisoner, Social Security, Bankruptcy appeals), with mandatory 3-page pre-motion letter and optional 3-page response due within 5 days.

In all cases except habeas corpus/prisoner petitions and Social Security and Bankruptcy appeals, a pre-motion conference must be requested before filing: i. Any motion pursuant to Fed. R. Civ. P. 12; ii. Any motion for a change of venue; iii. Any motion to remand; or iv. Any motion to amend a pleading pursuant to FED. R. CIV. P. 15 where leave of court is required. The pre-motion conference may be held in person or by telephone, at the discretion of the Court. To request a pre-motion conference, a party shall file and serve a letter not to exceed three (3) pages in length setting forth the basis for the anticipated motion, and affirming that they have conferred with all parties regarding the relief to be requested. All parties may, but are not required to, serve and file a letter response, not to exceed three (3) pages within five (5) days from filing of the notification letter. The Court may act on the initial request before a response is filed. Rule 12(a) prescribes time requirements for the filing of answers and for the filing of motions permitted under Rule 12. For the purposes of these timing requirements, a pre-motion conference letter requesting permission to file a motion permitted by the Rule shall be considered the equivalent of the motion itself. Compliance with this procedure shall not be deemed a waiver of any parties’ defenses as to insufficient service of process or lack of personal jurisdiction.

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Page 6 | MOTION PRACTICE

Pre-motion conference letters are not required for motions under Fed. R. Civ. P. 50, 59, or 60.

Note that these provisions do not apply to motions other than those specifically enumerated. For example, letters requesting pre-motion conferences are not required for motions pursuant to Fed. R. Civ. P. 50, 59 and 60, and counsel should be aware that the Court of Appeals will not accept an argument that compliance with district court motion rules should excuse noncompliance with Fed. R. App. 4.

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Page 7 | Pre-Motion Conference Provisions

Parties must confer with opposing counsel on all motions to reach agreement on requested relief.

Counsel and pro se parties must make serious and timely efforts to confer with opposing counsel on all motions to try to reach agreements on the relief requested.

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Page 7 | C. Requirements for All Motions

Parties filing discovery or scheduling motions must arrange a pre-motion conference with the Court before submitting motion papers.

Any party wishing to make a discovery or scheduling motion should arrange for a conference with the Court before submission of any motion papers.

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Page 8 | C. Requirements for All Motions

Nonmovant responses due 21 days after motion filing, replies due 7 calendar days after response; no sur-replies without leave of court.

Unless the Court issues a briefing schedule, responses by the nonmovant must be filed within 21 days of the motion. Movant may file a reply within seven calendar days after the non-movant's response. No further briefing, including supplements and sur-replies, should be filed without leave of Court. The Court will usually decline to consider such additional briefing. When circumstances dictate, the Court may consider and rule upon a motion prior to expiration of the 21-day period.

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Page 8 | C. Requirements for All Motions

Counsel must confer in good faith to resolve discovery/scheduling disputes; if unresolved, must seek Court conference via joint letter with required content.

Counsel are responsible for conferring in good faith to resolve discovery and scheduling disputes. If counsel for the parties are unable to reach an agreement, a conference with the Court must be sought by a joint letter filed with the Court. The parties should file a joint letter that does not exceed 2 pages, outlining the issues. The letter MUST specify the date, time and place of the parties’ prior out-of-court discovery or scheduling discussion(s), the results of the discussions, and the names of all counsel or pro se parties participating therein. If counsel has been unable to confer because of the unavailability or unwillingness of certain counsel or pro se parties to do so, the statement shall recite the facts concerning attempts to confer.

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Page 9 | DISCOVERY AND SCHEDULING DISPUTES

Separate requests for oral argument on motions are not required; the Court will notify counsel if oral argument is warranted.

Separate requests for oral argument on motions are not necessary. The Case Manager will notify counsel if the Court determines that oral argument would be beneficial.

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Page 8 | C. Requirements for All Motions

Adjournment & Extension Requirements

Continuances and extensions are granted only at the Court’s discretion; joint agreements are not binding, and continuances for discovery disputes are rarely approved.

Agreements or joint motions among counsel for continuance or extensions of deadlines are not binding on the Court. Motions for continuance will be granted only at the Court’s discretion. The Court’s trial settings are usually firm, and continuances will rarely be granted because of discovery disputes.

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Page 4 | CONTINUANCES

Extensions require good cause; first unopposed pre-deadline extensions usually granted, second case-by-case, third disfavored; post-deadline motions comply with FRCP 6(b)(2).

Counsel and pro se parties are directed to Federal Rule of Civil Procedure 6(b)(1), which allows extension of deadlines upon a showing of “good cause.” In most cases, the Court will be inclined to grant the first, unopposed motion to extend a particular deadline as a matter of courtesy, so long as that motion recites sufficient cause and is submitted before the deadline in question. Second motions for extension of time will be granted on a case-by-case basis. Third motions for extension of time are disfavored but will be granted in extraordinary circumstances. Motions made after a deadline should comply with Federal Rule of Civil Procedure 6(b)(2).

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Page 8 | C. Requirements for All Motions

Requests to modify Docket Control Order dates must include recommendations for all subsequent date adjustments.

If a change to an existing Docket Control Order is requested, all parties shall submit recommendations for adjusting all dates in the Docket Control Order that follow the date sought to be modified.

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Page 12 | 8. INITIAL PRETRIAL CONFERENCES AND DOCKET CONTROL ORDERS

Motions to extend Docket Control Order deadlines or cut-off dates are not classified as emergencies.

Motions for extension of deadlines or cut-off dates in the Docket Control Order are not emergencies.

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Page 4 | EMERGENCIES

Chambers Communication Rules

Case status information must be obtained from CM/ECF, PACER, or the Clerk's Office rather than chambers staff.

Information about the status of documents, entry of orders, or docket entries should be obtained from the CM/ECF or Pacer Systems, or if absolutely necessary, from the United States District Clerk's Office ((713) 250-5500).

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Page 3 | CONTACT WITH COURT PERSONNEL

All written correspondence with the Court must be sent to Case Manager Kimberly Picota via mail to the provided address.

Correspondence with the Court must be sent to the Case Manager as follows: Kimberly Picota, Case Manager to Judge George C. Hanks, Jr. United States Courthouse, 515 Rusk St., Room 5300, Houston, TX 77002, Or by email: Kimberly_Picota@txs.uscourts.gov

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Page 3 | CONTACT WITH COURT PERSONNEL

Case-related telephone inquiries must be directed to the Case Manager, not law clerks or the Judge.

Any case-related telephone and email inquiries should be made to the Case Manager. Inquiries should not be made to the Court’s law clerks, nor to the Judge.

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Page 3 | CONTACT WITH COURT PERSONNEL

Emergency applications for immediate relief must be filed via CM/ECF with all communications routed through the Case Manager, including affirmation of opposing party contact.

Applications for immediate relief, including restraining orders, must be filed electronically through the CM/ECF system and all related communications with the Court must be through the Case Manager. Such applications shall be presented to the Court by the Case Manager following counsel's affirmation that the opposing party has been contacted and that both parties can be available for a conference before the Court, or an explanation of why such contact has not been made.

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Page 4 | EMERGENCIES

Out-of-town counsel must request telephone appearance via email to Case Manager with as much advance notice as possible; dispositive/contested motions and pro se matters are preferred in person.

Out-of-town counsel wishing to appear at a conference or hearing by telephone must submit a written request by email to the Case Manager as far in advance of the conference as reasonably possible. The Court will attempt to accommodate such requests, if feasible. The Court’s preference, however, is to set dispositive or contested motions in person. Counsel appearing by telephone should use a landline. Matters involving pro se parties will be heard in person, unless stated otherwise.

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Page 5 | APPEARANCES AND CONFERENCES

Counsel and pro se parties must notify the Case Manager in writing immediately upon settlement of any matter before the court.

Counsel and pro se parties shall notify the Case Manager immediately in writing of the parties’ settlement of any matter before the court. Upon receipt of a notice that the entire case is settled, the Court may enter a conditional order of dismissal.

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Page 5 | APPEARANCES AND CONFERENCES

Chambers staff will not take telephone messages for counsel or parties, and counsel are prohibited from requesting use of telephones in Chambers.

Telephone messages for counsel or parties will not be taken by the Judge=s staff, and counsel shall refrain from requesting use of telephones in Chambers.

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Page 17 | Court Telephones

Counsel must immediately notify the Case Manager by letter or email upon settlement and file the notice on CM/ECF.

Upon settlement of any case, counsel must immediately notify the Case Manager in writing, by letter, or by email (cm4147@txs.uscourts.gov), and such notice shall also be filed on CM/ECF.

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Page 19 | SETTLEMENTS AND ORDERS OF DISMISSAL

The Case Manager will not respond to casual telephone inquiries regarding the status of motions or cases.

The Court's caseload does not allow the Case Manager to respond to casual telephone inquiries about the status of motions or cases.

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Page 3 | CONTACT WITH COURT PERSONNEL

Junior Lawyer Participation Incentives

Court encourages lawyers with less than seven years of experience to conduct hearings, especially for motions they drafted or contributed to, to provide substantive speaking opportunities.

for young lawyers (i.e., lawyers practicing for less than seven years) to conduct hearings before the Court, particularly for motions where the young lawyer drafted or contributed significantly to the underlying motion or response. The Court believes it is crucial to provide substantive speaking opportunities to young lawyers, and that the benefits of doing so will accrue to young lawyers, to clients, and to the profession generally. Thus, the Court encourages all lawyers practicing before it to keep this goal in mind.

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Page 9 | APPEARANCES AND CONFERENCES

About United States District Judge George C. Hanks Jr.

**United States District Judge George C. Hanks, Jr.** was appointed to the Southern District of Texas by President Barack Obama in 2015. Judge Hanks serves in the Houston Division of the Southern District of Texas. He maintains specialized discovery protocols for a wide range of civil case types including premise liability, employment, FLSA, insurance property damage, business interruption insurance, and residential mortgage cases. **Career** - United States District Judge, Southern District of Texas, Houston Division (2015–present)

**Division:** Houston **Courthouse:** Bob Casey United States Courthouse, 515 Rusk Street, Room 6202, Houston, Texas 77002 **Phone:** (713) 250-5757 **Chambers Staff** - Case Manager: Kimberly Picota, (713) 250-5406, cm4147@txs.uscourts.gov - Judicial Assistant: Jeanette Gonzalez, (713) 250-5473, Jeanette_gonzalez@txs.uscourts.gov - Law Clerk: Leo McKinney - Law Clerk: Eva Robins

Common questions about Judge George C. Hanks Jr.'s rules

Are courtesy copies required for Judge George C. Hanks Jr.?

Courtesy-copy rule applies when a filing is >= 50 pages. Details: delivery promptly, by hand delivery. Courtesy copies of documents 50 or more pages (including exhibits and attachments) must be promptly delivered to the Houston Clerk’s Office.

View ruleSource: page 4, section COURTESY COPIES OF CERTAIN DOCUMENTS REQUIRED

Does Judge George C. Hanks Jr. require a pre-motion conference or letter before filing a motion?

Yes. A pre-motion letter is required for rule 12, venue change, remand, and rule 15 leave. Details: 3 pages, response due in 5 days. Pre-motion conference required before filing specified motions (except in habeas, prisoner, Social Security, Bankruptcy appeals), with mandatory 3-page pre-motion letter and optional 3-page response due within 5 days.

View ruleSource: page 6, section MOTION PRACTICE

What page or word limits apply to letter before Judge George C. Hanks Jr.?

Judge George C. Hanks Jr.'s rule states these limits: 2 pages. Joint letters filed for discovery/scheduling dispute conferences must not exceed 2 pages.

View ruleSource: page 9, section DISCOVERY AND SCHEDULING DISPUTES

What page or word limits apply to brief before Judge George C. Hanks Jr.?

Judge George C. Hanks Jr.'s rule states these limits: 25 pages. Motions, briefs, and memoranda are limited to 25 pages, 13-point font, double-spaced, 1-inch margins without leave of court.

View ruleSource: page 10, section MOTIONS AND MEMORANDA OF LAW

What formatting rules apply to filings before Judge George C. Hanks Jr.?

Judge George C. Hanks Jr.'s formatting rule includes defendant must file defendant’s portions in joint pretrial order format if plaintiff fails to file timely. Defendants must file their Joint Pretrial Order portions in proper format if plaintiffs fail to file timely.

View ruleSource: page 12, section 9. REQUIRED PRETRIAL AND TRIAL MATERIALS

What must be included with discovery response filings before Judge George C. Hanks Jr.?

The rule identifies required filing content or certificates. A responding party providing a partial or incomplete answer or production must state the reason it is incomplete.

View ruleSource: page 3, section PART 2: DEFINITIONS AND INSTRUCTIONS

What must be included with joint pretrial order filings before Judge George C. Hanks Jr.?

The rule identifies required filing content or certificates. Joint Pretrial Order must briefly state contested legal issues.

View ruleSource: page 24, section Contested Issues of Law

How may parties contact Judge George C. Hanks Jr.'s chambers?

The rule addresses phone communications with Judge George C. Hanks Jr.'s chambers. Case-related telephone inquiries must be directed to the Case Manager, not law clerks or the Judge.

View ruleSource: page 3, section CONTACT WITH COURT PERSONNEL

How does Judge George C. Hanks Jr. handle sealed or redacted filings?

A motion to seal is required for covered sealed filings before Judge George C. Hanks Jr.. Designated Material filed with the Court is public unless a party moves to file it under seal, and this Order does not automatically seal it.

View ruleSource: page 3, section 14

How do I request an adjournment or extension before Judge George C. Hanks Jr.?

Advance notice is not fully stated in the structured details. Continuances and extensions are granted only at the Court’s discretion; joint agreements are not binding, and continuances for discovery disputes are rarely approved.

View ruleSource: page 4, section CONTINUANCES

Does Judge George C. Hanks Jr. require motion papers to be bundled?

Yes. Judge George C. Hanks Jr. requires bundling for covered papers. Joint Trial Notebook must be submitted jointly; if counsel cannot cooperate, each side submits its own notebook and exhibits.

View ruleSource: page 14, section REQUIRED PRETRIAL AND TRIAL MATERIALS

What filing deadlines does Judge George C. Hanks Jr. set?

The Insurer must provide its Initial Discovery responses within 45 days after submitting a responsive pleading or motion, unless the court orders otherwise.

View ruleSource: page 7, section PART III: INFORMATION AND DOCUMENTS TO BE PRODUCED BY THE INSURER

Does Judge George C. Hanks Jr. encourage junior lawyer participation?

Yes. Judge George C. Hanks Jr.'s rules include a junior lawyer participation incentive. Court encourages lawyers with less than seven years of experience to conduct hearings, especially for motions they drafted or contributed to, to provide substantive speaking opportunities.

View ruleSource: page 9, section APPEARANCES AND CONFERENCES
Complete rules summary for Judge George C. Hanks Jr.

A responding party providing a partial or incomplete answer or production must state the reason it is incomplete.

Joint Pretrial Order must briefly state contested legal issues.

Joint letters filed for discovery/scheduling dispute conferences must not exceed 2 pages.

Case-related telephone inquiries must be directed to the Case Manager, not law clerks or the Judge.

The Case Manager will not respond to casual telephone inquiries regarding the status of motions or cases.

Case status information must be obtained from CM/ECF, PACER, or the Clerk's Office rather than chambers staff.

All written correspondence with the Court must be sent to Case Manager Kimberly Picota via mail to the provided address.

Courtesy copies of documents 50 or more pages (including exhibits and attachments) must be promptly delivered to the Houston Clerk’s Office.

Courtesy copies of documents for matters being heard by the Court must be delivered to the Houston Clerk’s Office within three days of filing.

Fax or email delivery of documents to Chambers is prohibited unless the Court provides specific authorization.

Emergency applications for immediate relief must be filed via CM/ECF with all communications routed through the Case Manager, including affirmation of opposing party contact.

Motions to extend Docket Control Order deadlines or cut-off dates are not classified as emergencies.

Continuances and extensions are granted only at the Court’s discretion; joint agreements are not binding, and continuances for discovery disputes are rarely approved.

Pre-motion conference required before filing specified motions (except in habeas, prisoner, Social Security, Bankruptcy appeals), with mandatory 3-page pre-motion letter and optional 3-page response due within 5 days.

Out-of-town counsel must request telephone appearance via email to Case Manager with as much advance notice as possible; dispositive/contested motions and pro se matters are preferred in person.

Counsel and pro se parties must notify the Case Manager in writing immediately upon settlement of any matter before the court.

Pre-motion conference letters are not required for motions under Fed. R. Civ. P. 50, 59, or 60.

Parties must confer with opposing counsel on all motions to reach agreement on requested relief.

All motions must include a certificate of conference detailing conferring efforts, opposition status, and contact attempts if opposition is uncertain.

All motions except those under FRCP 56 must be accompanied by a separate proposed order.

Proposed orders are prohibited from containing a bare signature block.

Nonmovant responses due 21 days after motion filing, replies due 7 calendar days after response; no sur-replies without leave of court.

Parties filing discovery or scheduling motions must arrange a pre-motion conference with the Court before submitting motion papers.

Separate requests for oral argument on motions are not required; the Court will notify counsel if oral argument is warranted.

Sealed documents in civil cases must be labeled with SEALED and the document title; docketing as solely 'SEALED DOCUMENT' requires court permission.

Extensions require good cause; first unopposed pre-deadline extensions usually granted, second case-by-case, third disfavored; post-deadline motions comply with FRCP 6(b)(2).

Court encourages lawyers with less than seven years of experience to conduct hearings, especially for motions they drafted or contributed to, to provide substantive speaking opportunities.

Counsel must confer in good faith to resolve discovery/scheduling disputes; if unresolved, must seek Court conference via joint letter with required content.

Counsel must use a numbering system for documents during discovery and pretrial process.

Motions, briefs, and memoranda are limited to 25 pages, 13-point font, double-spaced, 1-inch margins without leave of court.

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