Judge Nicholas Jon Ganjei
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
All filings
- As Directed
Courtesy copies
Emergency Motions
- 1 copy • Email • Upon Filing
Exhibit
- 3 copies • Simultaneous With Exhibit List Submission
Adjournments
- Modification of the Scheduling Order requires a motion establishing good cause, and requested changes must include recommended dates for all adjusted deadlines after the first modification.
- Parties may extend discovery deadlines by agreement without court approval if the extension does not impact the Scheduling Order or other court-set deadlines.
- The Court will accommodate vacation and family-related continuance requests if made well in advance of the hearing or trial.
- +5 more
Request must include
Communication
Chambers
Phone
Chambers
Clerk
Page & Word Limits2 rules
Machine summary. Not checked yet.Mandatory?
c. Page Limits: Limit any motion or response to 5,000 words (approximately twenty-five pages). Limit any reply to 2,000 words (approximately ten pages). Do not file a sur-reply absent permission. Provide a certificate of word count following the signature block. Reliance on word-processor register is sufficient in this regard. Word limits do not include the case caption, table of contents, table of authorities, signature block, or certificates. Word limits are rarely extended. Anticipate and seek resolution of any motion for extension well in advance of the filing deadlines.
Summary: Motions and responses limited to 5000 words; replies limited to 2000 words. Sur-replies prohibited without permission. Word count certificate required. Exclusions: caption, TOC, TOA, signature, certificates. Word limit extensions rarely granted.
Brief
5,000 words
Reply Brief
2,000 words
Machine summary. Not checked yet.Mandatory?
To obtain permission, the party seeking relief must submit a letter not exceeding two pages.
Summary: Pre-motion letters for discovery/scheduling disputes are limited to 2 pages.
Letter
2 pages
Document Format Requirements21 rules
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.
Machine summary. Not checked yet.Mandatory?
Trial Deposition excerpts when objections have been lodged. Highlight the objections and the questions/answers to which those objections are directed.
Summary: Trial deposition excerpts with objections must have the objections and corresponding questions/answers highlighted.
Machine summary. Not checked yet.Mandatory?
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, stored in binders no larger than 4 inches, and marked with the CM/ECF docket number unless urgent.
Machine summary. Not checked yet.Mandatory?
Use Form 5 to prepare draft proposed orders.
Summary: All draft proposed orders must be prepared using Form 5.
Machine summary. Not checked yet.Mandatory?
b. Style: Use American letter-size paper, 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. Acceptable fonts are Times New Roman size 13 or larger, Book Antiqua size 12 or larger, and Century Schoolbook size 12 or larger.
Summary: Motion papers must use letter-size paper, 1-inch margins (0.5 inches for footnotes/headers/footers), double spacing (with exceptions), and specified fonts/sizes.
Machine summary. Not checked yet.Mandatory?
g. Supporting Evidence: Supply affidavits, deposition testimony excerpts, and supporting documents as separate exhibits to the filing. Provide a cover sheet to identify and separate each exhibit. Prepare and submit a table of contents when attachments are numerous. Upload exhibits as separate attachments during filing on the CM/ECF system.
Summary: Supporting evidence must be filed as separate exhibits with cover sheets; numerous exhibits require a table of contents; exhibits must be uploaded as separate CM/ECF attachments.
Machine summary. Not checked yet.Mandatory?
Use Form 6 to prepare a Joint Pretrial Order. Adapt this form within reason to accommodate the nature and complexity of the case.
Summary: Civil Joint Pretrial Orders must be prepared using Form 6, adaptable within reason for case complexity.
Machine summary. Not checked yet.Mandatory?
Use Form 7 to prepare a trial exhibit list. Also refer to Section 12. Each offering party must mark its own exhibits with the party’s name, case number, and exhibit number. List only those exhibits intended in good faith for use during trial.
Summary: Trial exhibit lists must use Form 7; exhibits must be marked with party name, case number, exhibit number, and only list exhibits intended for trial use.
Machine summary. Not checked yet.Mandatory?
Use Form 8 to prepare the trial witness list.
Summary: Trial witness lists must be prepared using Form 8.
Machine summary. Not checked yet.Mandatory?
Use Form 9 to prepare deposition designations.
Summary: Deposition designations must be prepared using Form 9.
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For bench trials, also offer the entire deposition marked as an exhibit.
Summary: For bench trials, the entire deposition must be offered marked as an exhibit.
Machine summary. Not checked yet.Mandatory?
Include a cover sheet with concise summary of topics for each witness, the first deposition page, and at least two pages prior to and after any designation. Highlight in contrasting colors to indicate all designated testimony, counter-designations, and objections. Use a condensed transcript (four pages to one) when available.
Summary: Deposition designations must include a cover sheet with required contents, use contrasting colors for designations/objections, and use condensed transcripts when available.
Machine summary. Not checked yet.Mandatory?
Do not make copies. Return all questionnaires on conclusion of jury selection.
Summary: Juror questionnaires must not be copied and must be returned after jury selection concludes.
Machine summary. Not checked yet.Mandatory?
In civil cases, counsel for Plaintiff must also submit a Word version by email to the Court’s Case Manager.
Summary: Civil cases require plaintiff's counsel to submit Word version of jury charge by email to Court's Case Manager.
DOCX
Machine summary. Not checked yet.Mandatory?
Identify by bold, italicized, or differently colored font any disputed language and which party requests each competing version.
Summary: Disputed language in joint proposed jury charge must be marked with bold, italic, or different color font, noting the requesting party.
Machine summary. Not checked yet.Mandatory?
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.
Summary: Agreed post-trial findings and conclusions must use black font; disagreed items must use different color font per party.
Machine summary. Not checked yet.Mandatory?
In civil cases, counsel for Plaintiff must also submit a Word version by email to the Case Manager.
Summary: Civil cases require plaintiff's counsel to submit a Word version of documents via email to the Case Manager.
DOCX
Machine summary. Not checked yet.Mandatory?
In criminal cases, counsel for Prosecution and Defense must each submit a Word version by email.
Summary: Criminal cases require prosecution and defense counsel to each submit a Word version of documents via email.
DOCX
Machine summary. Not checked yet.Mandatory?
Use the forms provided on the Court’s website: https://www.txs.uscourts.gov/page/district-magistrate- judges-procedures-schedules.
Summary: Joint Pretrial Orders must use the forms provided on the Court’s website.
Machine summary. Not checked yet.Important?
f. Citations: Provide pinpoint citation for all legal authority. For evidence, 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 required for all legal authority; specific citation formats required for evidence; Bates numbers required where available.
Machine summary. Not checked yet.Important?
h. Copies of Legal Authority: 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 authorities not on Westlaw or Lexis must be appended as an appendix with a cover sheet.
Document Filing Requirements48 rules
Checked against the court's document on Oct 4, 2026Mandatory
The pretrial order must identify each party and its counsel in separate paragraphs and list counsel’s addresses, telephone numbers, and email addresses.
Identify in separate paragraphs each party and its respective counsel. List the addresses, telephone numbers, and e-mail addresses of counsel.
Document Type
Pretrial Order
Checked against the court's document on Oct 4, 2026Mandatory
The pretrial order must identify pending motions other than motions in limine.
Identify any pending motions other than motions in limine.
Document Type
Pretrial Order
Checked against the court's document on Oct 4, 2026Mandatory
Each party must file and attach a separate trial exhibit list using Form 7.
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
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, following the specified procedure sections.
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
Checked against the court's document on Oct 4, 2026Mandatory
The Joint Pretrial Order must include the specified witness-disclosure statement, including its 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
Joint Pretrial Order
Checked against the court's document on Oct 4, 2026Mandatory
Each party must file and attach any intended deposition designations as a separate document, following Section 22 and using Form 9.
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
Checked against the court's document on Oct 4, 2026Mandatory
For bench trials, each party must separately file proposed findings of fact and conclusions of law and attach them to the Joint Pretrial Order.
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
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
Not confirmed. Read the court's wording below.Mandatory?
Identify all claims remaining including the party affected.
Summary: The pretrial order must identify all remaining claims and the party affected by each.
Document Type
Pretrial Order
Not confirmed. Read the court's wording below.Mandatory?
Set forth a brief, agreed statement of the case. In a jury trial, the Court will read this statement to the jury panel during voir dire examination. Include names, dates, and relevant places. Briefly state the parties’ contentions and the issues requiring resolution at trial.
Summary: The pretrial order must include a brief agreed statement of the case, with names, dates, relevant places, the parties’ contentions, and the issues to be resolved at trial.
Document Type
Pretrial Order
Not confirmed. Read the court's wording below.Mandatory?
Briefly state why the Court has jurisdiction of the subject matter and the parties. Identify any unresolved jurisdictional questions or whether any party disagrees.
Summary: The pretrial order must briefly state the basis for subject-matter and personal jurisdiction and identify unresolved jurisdictional questions or any party’s disagreement.
Document Type
Pretrial Order
Not confirmed. Read the court's wording below.Mandatory?
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.
Summary: The Joint Pretrial Order must list each intended case-in-chief witness’s name, address, and a brief description of the testimony in separate paragraphs.
Document Type
Joint Pretrial Order
Not confirmed. Read the court's wording below.Mandatory?
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.
Summary: Each party must file and attach a separate trial witness list using Form 8 and comply with Section 21 of the Court’s procedures.
Document Type
Joint Pretrial Order
Machine summary. Not checked yet.Mandatory?
The removing party must file the certificate of service and provide the additional information within ten days of removal.
Summary: Removing parties must file a certificate of service and additional required information within ten days of removal.
Document Type
Notice Of Removal
Machine summary. Not checked yet.Mandatory?
All counsel who wish to receive CM/ECF notices must file a notice of appearance. Inclusion of names in the signature block of a pleading does not constitute notice of appearance.
Summary: Counsel seeking to receive CM/ECF notices must file a notice of appearance; inclusion in a pleading’s signature block is insufficient.
Document Type
Notice Of Appearance
Machine summary. Not checked yet.Mandatory?
All parties must sign and counsel for Plaintiff must file a single, completed joint plan. Follow Rule 26(f) in all respects.
Summary: All parties must sign the joint discovery/case management plan, plaintiff’s counsel must file a single completed plan, and the plan must comply with Rule 26(f).
Document Type
Joint Discovery Case Management Plan
Machine summary. Not checked yet.Mandatory?
Include the applicant’s averment of familiarization with these procedures and the Local Rules with any application for pro hac vice admission.
Summary: Pro hac vice admission applications must include an averment of the applicant’s familiarization with court procedures and Local Rules.
Document Type
Pro Hac Vice Application
Machine summary. Not checked yet.Mandatory?
The parties must jointly confer in good faith regarding appropriate terms for a protective order and file either a joint or opposed motion for entry of a protective order with the proposed order as an exhibit.
Summary: Motions for entry of a protective order must include the proposed order as an exhibit.
Document Type
Protective Order Motion
Machine summary. Not checked yet.Mandatory?
If the Court has not addressed a pending motion that a party believes needs imminent attention, a party may file a motion requesting a ruling. The motion should explain the posture of the case and the pending motion, and explain why the pending motion needs to be addressed quickly.
Summary: A party may file a motion requesting a ruling on a pending motion, which must explain the case posture, the pending motion, and the need for expedited attention.
Document Type
Motion Requesting Ruling Pending Motion
Machine summary. Not checked yet.Mandatory?
The Court may strike motions that do not include a certificate of conference.
Summary: All motions must include a certificate of conference, or risk being struck.
Document Type
Motion
Machine summary. Not checked yet.Mandatory?
The Court may strike motions that do not include this in the certificate of conference.
Summary: Rule 12(b)(6) and 12(c) motions must include identification of issues and good faith conferral in the certificate of conference.
Document Type
Motion
Machine summary. Not checked yet.Mandatory?
Include a proposed order granting or denying the requested relief with all non-dispositive motions and oppositions.
Summary: All non-dispositive motions must include a proposed order.
Document Type
Motion
Machine summary. Not checked yet.Mandatory?
Provide a certificate of word count following the signature block. Reliance on word-processor register is sufficient in this regard.
Summary: A word count certificate must be included following the signature block of motion papers; word-processor count is acceptable.
Document Type
Brief
Machine summary. Not checked yet.Mandatory?
e. Briefing Requirements: All motions or similar filings must contain the following: • A statement of the nature and stage of the proceeding; • A statement of the facts necessary to resolution of the motion; • A statement of the issues requiring resolution; • A short statement (including citations to legal authority) of the standard of review for each issue; • A statement of the facts necessary to resolution of the motion; • An argument devoted to relevant, persuasive legal authority; • A short conclusion stating the precise relief sought; • Succinct headings dividing the motion into the above parts. • A table of contents setting forth page numbers of all sections and point headings; • A table of authorities organizing in categories and arranging alphabetically all cited cases, statutes, rules, textbooks, and other authorities; • A concise summary of the argument immediately prior to the argument in full; and • Succinct point headings dividing the argument into separate components.
Summary: All motions must contain required statements (nature of proceeding, facts, issues, standard of review, argument, relief), table of contents, table of authorities, and argument summary.
Document Type
Brief
Machine summary. Not checked yet.Mandatory?
a. Separate Memorandum Not Allowed: File a single pleading. Do not file a separately designated Memorandum of Law. Include necessary factual support, legal argument, and requested relief in the motion itself.
Summary: Motion papers must be a single pleading with no separate Memorandum of Law; all factual support, legal argument, and requested relief must be included in the motion.
Document Type
Motion
Machine summary. Not checked yet.Mandatory?
All lead counsel must sign the Joint Pretrial Order. Primary responsibility rests with Plaintiff’s counsel to ensure timely filing as established by rule unless otherwise set by Court order. On any failure by Plaintiff’s counsel, Defendant’s counsel must timely file Defendant’s portions.
Summary: Joint Pretrial Orders must be signed by all lead counsel; plaintiff's counsel has primary filing responsibility, defendant's counsel must file on plaintiff's failure.
Document Type
Joint Pretrial Order
Machine summary. Not checked yet.Mandatory?
The parties must jointly prepare and provide written certification of completeness.
Summary: Parties must jointly prepare and submit a written certification of completeness for admitted exhibits for jury deliberation.
Document Type
Certificate
Machine summary. Not checked yet.Mandatory?
Each party must file a list of witnesses it intends in good faith to call in its case-in-chief. State for each witness: Full name, address, and identifying information; A concise summary of the expected testimonial topics; Whether the witness will testify live or by deposition; and Whether testimony is fact, expert, or record custodian.
Summary: Trial witness lists must include specified details for each witness, including name, address, testimony summary, testimony type, and witness classification.
Document Type
Witness List
Machine summary. Not checked yet.Mandatory?
File separate motions in limine with a matching proposed order on the same date the Joint Pretrial Order is filed.
Summary: Motions in limine must include a matching proposed order filed on the same date as the Joint Pretrial Order.
Document Type
Motion In Limine
Machine summary. Not checked yet.Mandatory?
The Prosecution must file a proposed jury charge based on the Fifth Circuit Pattern Jury Instructions and supported modifications.
Summary: Criminal cases require Prosecution to file proposed jury charge based on Fifth Circuit Pattern Jury Instructions with supported modifications.
Document Type
Proposed Jury Charge
Machine summary. Not checked yet.Mandatory?
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.
Summary: Joint proposed jury charge must note agreed instructions in headings; disagreed instructions require each party to submit their own version in order.
Document Type
Joint Proposed Jury Charge
Machine summary. Not checked yet.Mandatory?
Identify with legal support any deviations from the pattern instructions; and
Summary: Deviations from Fifth Circuit Pattern Jury Instructions in joint proposed charge must be identified with legal support.
Document Type
Joint Proposed Jury Charge
Machine summary. Not checked yet.Mandatory?
The Defense must file objections or its own supported modifications.
Summary: Criminal cases require Defense to file objections or supported modifications to proposed jury charge.
Document Type
Proposed Jury Charge
Machine summary. Not checked yet.Mandatory?
Present each instruction, definition, and question with supporting legal authority;
Summary: All instructions, definitions, and questions in joint proposed jury charge must include supporting legal authority.
Document Type
Joint Proposed Jury Charge
Machine summary. Not checked yet.Mandatory?
Each side must provide supporting legal authority for all requested instructions, definitions, and questions.
Summary: All requested instructions, definitions, and questions in criminal jury charge must include supporting legal authority.
Document Type
Proposed Jury Charge
Machine summary. Not checked yet.Mandatory?
File a Joint Proposed Charge: File a unified proposed charge even when not agreed in full.
Summary: Civil cases require filing a unified joint proposed jury charge even if not fully agreed.
Document Type
Joint Proposed Jury Charge
Machine summary. Not checked yet.Mandatory?
Submit a complete joint charge with the proposed instructions in the order that you would like them read to the jury.
Summary: Joint proposed jury charge must include all instructions in the order they are to be read to the jury.
Document Type
Joint Proposed Jury Charge
Machine summary. Not checked yet.Mandatory?
Use the Fifth Circuit Pattern Jury Instructions whenever possible;
Summary: Joint proposed jury charge must use Fifth Circuit Pattern Jury Instructions whenever possible.
Document Type
Joint Proposed Jury Charge
Machine summary. Not checked yet.Mandatory?
Proposed Conclusions of Law: Each party must cite legal authority to support all proposed conclusions of law it seeks at trial. Specify agreed propositions of law. At a minimum, address the prima facie elements of each cause of action and defense, the relation of necessary evidence to those elements, necessary legal definitions, all components of damages, and methods of calculations of damages.
Summary: Proposed conclusions of law must cite legal authority, specify agreed propositions, and address cause of action elements, evidence, definitions, and damages.
Document Type
Proposed Conclusions Of Law
Machine summary. Not checked yet.Mandatory?
Required Filings: Each party must file proposed findings of fact and conclusions of law at the time the Joint Pretrial Order is filed.
Summary: Parties must file proposed findings of fact and conclusions of law when Joint Pretrial Order is filed.
Document Type
Proposed Findings Of Fact And Conclusions Of Law
Machine summary. Not checked yet.Mandatory?
Proposed Findings of Fact: Each party must specify all proposed findings it anticipates establishing at trial. To the extent possible, cite deposition testimony, expected witness testimony, exhibits, or other evidence to support each proposed finding. Specify stipulated or agreed facts.
Summary: Proposed findings of fact must specify all anticipated findings, cite supporting evidence, and note stipulated facts.
Document Type
Proposed Findings Of Fact
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
Machine summary. Not checked yet.Mandatory?
The parties must discuss at the Rule 26(f) meeting and include in the CMP and Proposed Scheduling Order filed with the Court all the matters listed in Rule 26(f) that apply to the case. In general, the Court expects the parties to discuss, address in their CMP, and be prepared to review with the Court, the topics that are set out below. a. The nature and basis of the parties’ claims and defenses, and any threshold issues that need to be resolved, such as jurisdiction or limitations. b. The parties’ plan for discovery needed to obtain the information that is relevant, not privileged, and proportional to the needs of the case. c. Whether there are issues or problems in the preservation, retrieval, review, disclosure, or production of discoverable information. d. Whether there are issues specifically relating to the disclosure or discovery of electronically stored information, including: i. the form or forms in which it should be produced; ii. the topics and the period for which discovery will be sought; iii. the sources of information or systems within a party’s control that should be searched; iv. issues relating to preserving, retrieving, reviewing, disclosing, or producing electronically stored information; and
Summary: CMP and Proposed Scheduling Order must include all applicable Rule 26(f) matters and listed topics.
Document Type
Cmp
Machine summary. Not checked yet.Mandatory?
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 financially interested entities are identified; unincorporated entity parties require citizenship of all members in certificate.
Document Type
Certificate Of Interested Parties
Machine summary. Not checked yet.Mandatory?
The parties must file the CMP and the proposed Scheduling Order no later than 14 days before the Scheduling Conference is scheduled.
Summary: CMP and Proposed Scheduling Order must be filed no later than 14 days before the Scheduling Conference.
Document Type
Cmp
Machine summary. Not checked yet.Mandatory?
The parties are to file with the Court only one CMP and one Proposed Scheduling Order. Both must be signed by counsel for all parties and by any unrepresented parties. Counsel for the plaintiff is responsible for filing the CMP and Proposed Scheduling Order. If the plaintiff is unrepresented, counsel for the represented parties have the responsibility for filing the CMP and Proposed Scheduling Order.
Summary: CMP must be signed by all counsel and unrepresented parties; only one CMP filed.
Document Type
Cmp
Machine summary. Not checked yet.Mandatory?
If the parties cannot agree on matters that must or should be addressed in the CMP or Proposed Scheduling Order, the disagreements must be set out clearly in the joint filing.
Summary: Disagreements on CMP or Proposed Scheduling Order matters must be clearly stated in the joint filing.
Document Type
Cmp
Filing & Service rules
Filing Timing and Cure Windows
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
Service and Proof of Service Rules
All exhibits must be exchanged no later than the date the Joint Pretrial Order is filed.
Exchange all exhibits no later than the date the Joint Pretrial Order is filed.
Not confirmed. Read the court's wording below. · Civil cases
Page 3 | Exhibits
Parties should agree on the form of exhibit exchange; absent agreement, use well-organized USB drives or a similar electronic transfer or download.
Seek agreement on the form of exchange. Absent agreement, exchange well-organized USB drives or provide for similar electronic transfer or download.
We could not find this wording in the court's document. Open the source before relying on it. · Civil cases
Page 3 | Exhibits
Courtesy Copy Requirements
Do not provide the Court copies of all exhibits; provide copies only of exhibits with objections lodged 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.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 3 | Exhibits
Emergency motions must be filed via CM/ECF, then a copy emailed to Case Manager upon filing; extension motions are not considered emergencies.
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
Courtesy copies are only required for trial deposition excerpts with objections (highlighted), sealed documents, joint pretrial orders, and other trial material.
When Required: Do not provide courtesy copies to the Court except for the following: • Trial Deposition excerpts when objections have been lodged. Highlight the objections and the questions/answers to which those objections are directed. • Documents filed under seal; and • Joint Pretrial Orders and other trial material.
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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 (not filed); copy all parties on transmittal letters without attachments.
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. Do not file transmittal letters. Mail or email a copy of such letters without attachments to all other parties.
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Page 6 | COURT COPIES
Courtesy copies must be submitted if required, following directions in Section 6.
i. Court Copies: Submit courtesy copies if required and as directed in Section 6.
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Page 16 | Motion Practice and Hearings
Joint trial notebook required; plaintiff/prosecution counsel must deliver three copies at least four business days before final pretrial conference or docket call.
Confer, prepare, and provide a joint trial notebook. Include each party’s materials paired together in the order listed above. In civil cases, include the Joint Pretrial Order as the first item. Counsel to plaintiff or prosecution must deliver three copies at least four business days prior to the final pretrial conference or docket call in the manner directed in Section 6.
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Page 18 | Required Pretrial Filings
Each party must submit all exhibits on a well-organized USB drive plus three paper copies per court copy rules.
Court Copies: Follow Section 19 regarding submission of all exhibit lists. In addition to the lists, each party must simultaneously submit all exhibits on a well-organized USB drive together with three copies in the manner directed in Section 6.
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Page 18 | Trial Exhibit Lists
Sealing & Redaction Procedures
Motion to seal required for any pleading, brief, or supporting material under seal; file unredacted material under seal, motion to seal with redacted version on public docket, and label under-seal filings with SEALED designation.
b. 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 material under seal. Seek permission by motion establishing good cause as follows, and refer to Le v. Exeter Finance Corp., 990 F.3d 410, 417–21 (5th Cir 2021). 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. c. Disposition: The Court promptly considers such motions and directs filings under seal or on the public docket as appropriate.
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Page 9 | Protective Orders and Filings Under Seal
Filing Bundling Requirements
Joint Pretrial Orders filed on CM/ECF must have Section 19 pretrial filings attached as exhibits.
When filing the Joint Pretrial Order on the CM/ECF system, attach the pretrial filings set out in Section 19 as exhibits.
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Page 17 | Joint Pretrial Orders in Civil Cases
Each party must file all required pretrial filings (exhibit list, witness list, etc.) on the date the Joint Pretrial Order is filed, unless the Court orders otherwise.
Unless otherwise set by Court order, on the date the Joint Pretrial Order is filed each party must file: • An exhibit list (Section 20); • A witness list (Section 21); • Designation of deposition excerpts (Section 22); • Motions in limine (Section 23); • Proposed topics and questions for voir dire (Section 24); • In jury trials, a proposed joint jury charge (Section 25); and • In bench trials, proposed findings of fact and conclusions of law • A trial memorandum of law identifying and addressing the legal propositions that are necessary to the disposition and relief sought in the case, with indication of those which are not in dispute.
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Page 17 | Required Pretrial Filings
Motions in limine must be filed separately; bundling of multiple motions in limine is prohibited.
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 22 | Motions In Limine
Post-trial joint proposed findings of fact and conclusions of law must be submitted as a single document.
Following trial and at the time directed by the Court, the parties shall file a joint proposed findings of fact and conclusions of law. Submit the proposed findings and conclusions as one document and in the order the parties believe makes the most sense.
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Page 24 | BENCH TRIALS
Pre-Motion Conference Requirements
Parties must jointly confer in good faith on protective order terms before filing a motion for entry of a protective order.
The parties must jointly confer in good faith regarding appropriate terms for a protective order and file either a joint or opposed motion for entry of a protective order with the proposed order as an exhibit.
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Page 8 | Protective Orders and Filings Under Seal
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 11 | DISCOVERY AND SCHEDULING DISPUTES
Initiating letter (max 2 single-spaced pages) required to bring discovery or scheduling dispute motions; responsive letters allowed, no replies.
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 11 | DISCOVERY AND SCHEDULING DISPUTES
Letter (max 3 single-spaced pages) required to request in camera review of privilege logs; lead counsel must confer first, limited to 20 documents, one letter per party.
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 receipt of any later privilege log.
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Page 12 | PRIVILEGE LOGS
Discovery or scheduling dispute motions may not be filed without prior permission under Section 13.
Do not bring a motion on discovery or scheduling disputes absent permission obtained under Section 13.
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Page 13 | 15. MOTION PRACTICE AND HEARINGS d. Motions on Discovery and Scheduling
Rule 56 motions require mediation/settlement conference within 45 days of filing, joint report after, motion not considered before report.
Private mediation or settlement conference before the Magistrate Judge is required within forty-five days of the filing of a summary judgment motion under Rule 56. Proceed as directed under Section 29. Failure to participate in good faith may subject a party to sanctions under Rule 16(f). Immediately submit a joint report verifying either success or declaration of impasse by the mediator or Magistrate Judge. Motions for summary judgment will not be considered before submission of this joint report.
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Page 13 | 15. MOTION PRACTICE AND HEARINGS c. Motions for Summary Judgment in Civil Cases
Before filing Rule 12(b)(6) or 12(c) motions, parties must identify issues and confer in good faith.
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.
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Page 13 | 15. MOTION PRACTICE AND HEARINGS b. Motions to Dismiss or for Judgment on the Pleadings in Civil Cases
Parties must make good faith efforts to resolve disputes before filing any motion.
Make serious, timely, good faith efforts to seek agreement on all disputed matters and requests for relief, including dispositive motions.
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Page 13 | 15. MOTION PRACTICE AND HEARINGS a. Conference and Certificate Required
Civil motion responses due 21 calendar days after motion, replies 10 days after response, sur-replies prohibited without advance permission.
File any response within twenty-one calendar days of the motion. File any reply within ten calendar days of the response. Do not file a sur-reply without advance permission.
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Page 14 | 15. MOTION PRACTICE AND HEARINGS f. Submission Date and Briefing Deadlines in Civil Cases
Contested motions in limine require a response filed within three 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 22 | Motions In Limine
Discovery and scheduling motions require prior permission via a 2-page pre-motion letter after lead counsel confer, with responsive letters allowed but no replies.
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. 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. 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 at CM_DJGanjei@txs.uscourts.gov.
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Page 7 | Discovery and Scheduling Motion Procedures
Pre-motion letter required for discovery/scheduling dispute motions, must include nature of dispute, issues, and contested matters; lead counsel must confer before involving court.
Lead counsel must personally confer on all discovery and scheduling disputes as a final attempt at resolution prior to involving the Court. 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
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Page 4 | 6. Pre-Motion Conferences Required for Discovery and Other Pretrial Disputes
For discovery/pretrial dispute letters, opposing party must submit a responsive letter of similar length; reply letters are prohibited.
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 5 | 6. Pre-Motion Conferences Required for Discovery and Other Pretrial Disputes
Counsel’s designated attorney-in-charge must appear at the Scheduling Conference; substitution requires good cause and motion filed well in advance.
Counsel’s designated attorney-in-charge must appear at the Scheduling Conference. The Court permits substitution of counsel for this conference only on showing of good cause. File and seek ruling on any such motion well in advance of the conference.
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Page 5 | 7. Responsibilities of Counsel and Pro Se Parties
For e-discovery disputes, each party must have a person with detailed knowledge of relevant systems available at any conference.
When the dispute includes discovery of electronic data, each party must have available at any conference a person with detailed knowledge of the computers and electronic databases in issue.
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Page 5 | 6. Pre-Motion Conferences Required for Discovery and Other Pretrial Disputes
Conference attendees must be familiar with the case, prepared to discuss motions/ADR, and authorized to bind the client.
Any counsel or pro se party who appears at the conference must be: a. Fully familiar with the facts and the law applicable to the case, including having interviewed their witnesses; b. Prepared to argue any pending motion and to discuss any anticipated motion; c. Prepared to discuss potential alternative dispute resolution methods suited to the case; and d. Authorized to bind the client on all matters discussed at the conference.
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Page 5 | 7. Responsibilities of Counsel and Pro Se Parties
Parties must attempt to resolve discovery and scheduling disputes without court intervention; bad faith may result in cost shifting.
Make a serious attempt to resolve all discovery and scheduling disputes without intervention by the Court. This includes disputes to compel or quash any discovery or for protection. Be pragmatic. Seek reasonable compromise. The Court may shift costs or order other relief against a party or counsel acting unreasonably or in bad faith.
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Page 11 | DISCOVERY AND SCHEDULING DISPUTES
Parties must have a person with detailed electronic data knowledge available at conferences on electronic discovery disputes.
When the dispute includes discovery of electronic data, each party must have available at any conference a person with detailed knowledge of the computers and electronic databases in issue.
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Page 12 | DISCOVERY AND SCHEDULING DISPUTES
Initiating letter not required for discovery relief motions against nonparties.
An initiating letter is not required to seek discovery relief against a nonparty.
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Page 12 | DISCOVERY AND SCHEDULING DISPUTES
Adjournment & Extension Requirements
Modification of the Scheduling Order requires a motion establishing good cause, and requested changes must include recommended dates for all adjusted deadlines after the first modification.
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 8 | Continuances
Agreed extensions of motion submission dates require notice by letter/email and a proposed order accounting for other deadlines.
Advise by letter or email of any agreed extension of the submission date. Provide a proposed order for any agreed extension must account for other deadlines set by the Court.
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Page 14 | 15. MOTION PRACTICE AND HEARINGS f. Submission Date and Briefing Deadlines in Civil Cases
Continuances of firm trial dates require good cause; other court trial settings are not good cause unless lead counsel commenced trial, and civil continuances are unlikely due to witness unavailability.
Continuance of firm trial dates is disfavored absent exigent circumstances, and parties should establish good cause in any motion seeking continuance. A trial setting in another court is not considered good cause unless lead or other primary counsel has commenced trial. Continuance of a trial setting is unlikely in civil cases due to witness unavailability. Anticipate testimony by stipulation or by oral or written deposition under Rules 27, 30, and 31.
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Page 17 | Continuances
Motions for extension of discovery must be filed sufficiently in advance to allow opposing counsel to respond before the 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 | 6. Pre-Motion Conferences Required for Discovery and Other Pretrial Disputes
Continuances based on failure to complete discovery are disfavored, with potential sanctions for discovery failures.
g. Discovery Continuances Disfavored: Continuances due to failure to complete discovery are disfavored. Rather than grounds for continuance, discovery failures may result in the striking of evidence, dismissal of claims, or the striking of defenses.
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Page 10 | Initial Disclosures and Commencement of Discovery in Civil Cases
Motions to extend word limits are rarely granted; must be sought well in advance of filing deadlines.
Word limits are rarely extended. Anticipate and seek resolution of any motion for extension well in advance of the filing deadlines.
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Page 15 | Motion Practice and Hearings
Parties may extend discovery deadlines by agreement without court approval if the extension does not impact 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 8 | Continuances
The Court will accommodate vacation and family-related continuance requests if made 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 8 | Continuances
Chambers Communication Rules
Inquiries about cases assigned to Judge Ganjei must be directed to the Case Manager by phone at (713) 250-5656.
Direct inquiries regarding any case assigned to Judge Ganjei to: Case Manager to Judge Nicholas J. Ganjei 515 Rusk Street, Room 9718 Houston, Texas 77002 (713) 250-5656 Email: CM_DJGanjei@txs.uscourts.gov
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Page 1 | Court Procedures
All emergency-related communications must be made through the Case Manager via telephone.
Make all related communications through the Case Manager via telephone or email.
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Page 4 | Emergencies
All informal communications to the Court must go through the Case Manager, using specified methods based on the purpose of the communication.
Direct all informal communications to 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
Letters or emails sent to the Court must copy all parties using the same delivery method; such letters/emails must not be filed on the CM/ECF system.
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. 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
Counsel may not initiate contact with Law Clerks except to return a message, and may only discuss the specific subject of the Law Clerk’s inquiry.
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
Parties must immediately email chambers upon resolving a pending motion before ruling.
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.
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Page 14 | 15. MOTION PRACTICE AND HEARINGS j. Resolution by Agreement
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 26 | Courtroom Procedures and Conduct
Pre-motion and responsive letters for discovery and scheduling motions must be emailed to the Court’s case manager at the specified address.
The foregoing letters should be sent by email to the Court’s case manager at CM_DJGanjei@txs.uscourts.gov.
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Page 7 | Discovery and Scheduling Motion Procedures
Pre-motion dispute letters must be emailed to the Court’s case manager at the provided address.
The foregoing letters should be sent by email to the Court’s case manager at CM_DJGanjei@txs.uscourts.gov.
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Page 5 | 6. Pre-Motion Conferences Required for Discovery and Other Pretrial Disputes
Parties must email chambers with reasons to request expedited decision on a motion.
Promptly advise by email of need for decision on an expedited basis or date certain. Provide reasons justifying prompt attention.
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Page 14 | 15. MOTION PRACTICE AND HEARINGS f. Submission Date and Briefing Deadlines in Civil Cases
For status inquiries, first check the District Court website and CM/ECF system; direct filing questions to the Office of the Clerk, not the Court.
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
Oral argument requests must be made by email with justifying circumstances; no guarantee of grant.
Counsel may jointly or individually advise the Court by email of any request for oral argument together with circumstances to justify the request. Counsel are advised not to assume that oral argument will be granted and should thus strive for sufficiency, clarity, and accuracy in their written submissions.
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Page 14 | 15. MOTION PRACTICE AND HEARINGS i. Oral Argument