Southern District of Texas Local Rules and Judge Filing Requirements

In minor-plaintiff cases with a potential conflict of interest between parents and the minor, counsel must jointly move for appointment of an attorney ad litem upon settlement or before any mediation/ADR.

Joint Pretrial Orders must list each party, counsel, counsel’s address, and telephone number in separate paragraphs.

Proposed conclusions of law must cite legal authority and specify agreed propositions of law.

Failure to timely object results in waiver/admission; failure to timely respond results in objection being sustained.

Motions must contain the arguments and relief sought; a separate memorandum of law must not be filed.

Substantive issues are prohibited in letters or emails to the Court; all letters must be filed with the Court; email correspondence may be docketed at the Court’s discretion.

Judge Hanen's chambers can be reached by phone at (713) 250-5908 at the United States Courthouse, 515 Rusk Street, Room 8631, Houston, Texas.

Case-related telephone inquiries must be directed to Case Manager Arturo Rivera at 713-250-5181.

Email correspondence with the Case Manager may be docketed at the Court's discretion.

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

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

Joint Pretrial Orders must use Form 12, adapted as needed for case complexity.

Civil cases require plaintiff's counsel to submit a Word version of documents via email to the Case Manager.

Courtesy copies of filings over 50 pages must be double-sided, submitted in a three-ring binder no larger than four inches, with exhibits tabbed at the right margin.

Restraining order and immediate relief applications must be filed with the District Clerk’s Office at the specified address.

Amicus briefs require leave by motion with the brief attached as an exhibit; party responses to amicus briefing are freely allowed.

Oral argument requests are not required; the Court will notify counsel if a motion hearing is deemed beneficial.

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

Parties must have a person with detailed knowledge of relevant electronic systems available at conferences for electronic data discovery 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.

Continuances not granted for prior trial settings unless attorney has commenced trial in another court.

Motions for extension of deadlines in the Scheduling and Docket Control Order are not emergencies and may not be treated as such.

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

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

Real time transcription requests require 21 calendar days' notice to the Court prior to trial.

Proposed voir dire questions must be filed with the Joint Pretrial Order (JPO).

Objections to deposition designations must be filed at least three business days before the final pretrial conference, and objecting counsel bears the burden of securing a ruling before trial begins.

Leave of court is required to add or amend invalidity contentions after the service deadline.

The U.S. Probation Office must incorporate the Paroline findings into the defendant's PSI within 14 days of the Government's filing of its Paroline memorandum.

Original documents offered must be filed as soon as practicable.

Parties must promptly forward courtesy copies to Chambers of documents pertaining to matters to be heard by the Court within seven days after the document is filed; absent compliance, the Court will not consider documents filed within seven days of a court appearance.

Parties must submit courtesy hard copies to the Case Manager if any part of a filing is sealed.

Moving party must provide 2 courtesy copies of Responsive Brief and exhibits to the Court.

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

Courtesy copy of non-paper exhibit must be mailed to the Court's specified address.

A party requiring authentication of an exhibit must notify offering counsel in writing within five days after the exhibit is listed and made available, and failure to object in writing before trial concedes authenticity.

Responses and hearing requests for motions to dismiss must be filed within 20 days after service.

Counsel must notify offering counsel in writing within 7 days of exhibit identification to require authentication, or risk admission of authenticity.

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

The amended pleading must be served on all parties under Fed. R. Civ. P. 5 within 14 days of the order granting leave to amend.

Appendices containing supporting affidavits, deposition excerpts, and discovery referred to in briefs are limited to 40 pages each.

Briefs and memoranda limited to 20 pages including case style, table of contents/authorities, and signature block, absent leave for extended briefing.

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

Motions/responses limited to 5,000 words; replies limited to 2,000 words.

Motions are limited to 20 pages.

Exhibits with personal data identifiers must comply with S.D. Texas General Order #2004-11 regarding sealing/redaction.

Only the confidential portions of court filings should be placed under seal where possible, with non-confidential portions remaining public.

Filing documents under seal requires a motion establishing good cause, with redacted versions filed publicly, unredacted versions filed under seal, and proper SEALED designation on CM/ECF.

Designated Material filed with the Court is sealed only upon motion, with no automatic sealing; specific procedures apply based on whether the Filing Party is the Designating Party.

Grand juror names must be kept confidential.

Briefs must be filed together with or incorporated within the related motion, response, or reply, and motions should incorporate their supporting briefs, authority, and pertinent exhibits.

Joint trial notebook required, materials paired in order listed; JPO first item in civil cases.

Counsel must provide the Court with a tabbed and indexed notebook copy of their exhibits prior to the Final Pretrial Conference.

Joint Exhibit List is encouraged where possible.

Motions to seal and all exhibits to motions to seal must be filed as a single, combined document.

Electronic filings must comply with the Administrative Procedures for Electronic Filing in Civil and Criminal Cases.

Initial disclosures must not be filed with the court.

Parties must file copies of all letters sent to the Court.

Proposed findings of fact must be submitted electronically and via email to the Case Manager.

All parties must file documents electronically through the CM/ECF system per Local Rule 5.1.

The Court strongly encourages giving lawyers with less than seven years' experience primary speaking roles in conferences, trials, and evidentiary presentations, and will consider such participation in deciding whether to grant oral argument on motions it would otherwise decide on the papers.

Court encourages opportunities for lawyers with fewer than 7 years of experience to conduct hearings, especially those who contributed to the underlying motion or response.

Young lawyers (practicing less than 7 years) are encouraged to conduct hearings, especially for motions they drafted or contributed to.

Junior lawyers (licensed fewer than 7 years) are encouraged to receive speaking roles, especially if they drafted the motion/response or prepared the witness.

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.

Debtors must pay the filing fee with the petition or promptly by the due date set in an installment-payment order.