Court Rules
Judge

Judge Erica R. Hughes

Individual Rules, Standing Orders & Policies

Harris County District Courts

Limits & Logistics

Courtesy Copies

Courtesy copies

  • Hand Delivery

Mandamus Petition

  • Hand Delivery

Motion With Hyperlinks

  • Hand Delivery

Proposed Findings Conclusions

  • Email

Adjournments

  • A summary-judgment motion cannot be passed; the party must proceed or withdraw, and any reset request must comply with Rule 166a and be authorized by it.

Request must include

Reason For Request

Communication

Phone

Clerk

832-927-2450
SchedulingEmergencies
Phone

Chambers

Scheduling
Filters:AllMandatoryImportantFormattingProposed OrdersExhibitsConferencesDiscoverySettlementSummary JudgmentTRO/Injunction

Document Format Requirements5 rules

FormattingCivil cases

Checked against the court's document on Oct 3, 2026Mandatory

Do not alter or mark exhibits during proceedings; altered exhibits will not be accepted.

Do not alter or mark through exhibits with pen/pencil/marker during court proceedings. Should this occur, the exhibit (s) will not be accepted.

Harris:section:40
|Sec8. TRIALS—A) Pretrial Orders/Exhibits/Motions in Limine
FormattingCivil cases

Checked against the court's document on Oct 3, 2026Important

Prepare an 8-by-11-inch exhibit for any blowup used.

Mark an 8 x 11 size exhibit for any blowup used.

Harris:section:40
|Sec8. TRIALS—A) Pretrial Orders/Exhibits/Motions in Limine
FormattingCivil cases

Not confirmed. Read the court's wording below.Mandatory?

Appear in person unless Judge Hughes has agreed to another method of appearance.

Summary: Appear in person unless Judge Hughes has agreed to another method.

Harris:section:40
|Sec7. HEARINGS—A) Appearance by Phone
FormattingCivil cases

Not confirmed. Read the court's wording below.Important?

Counsels are required to wear business attire for all hearings, whether conducted in the courtroom or via Zoom. Business attire includes a suit or comparable professional courtroom attire customarily worn in a trial court. Men are required to wear a tie.

Summary: Counsel must wear business attire at all hearings, including hearings by Zoom, and men must wear a tie.

Harris:section:40
|Sec2. COURT ATTIRE
FormattingCivil cases

Not confirmed. Read the court's wording below.Note?

The court finds that the best and least expensive practice (this is not required) is to create .pdf (Adobe) files of these filings and the exhibits and exchange them on a flash drive or by sending them to opposing counsel an e-mail with attachments. A link to a cloud-based version of these documents is also acceptable.

Summary: Although not required, the Court considers PDF exchange by flash drive, email attachments, or a cloud link the best and least expensive practice.

Required Format

PDF

Harris:section:40
|Sec8. TRIALS—A) Pretrial Orders/Exhibits/Motions in Limine

Document Filing Requirements48 rules

Filing RequirementsCivil cases

Checked against the court's document on Oct 3, 2026Mandatory

A response filed after its deadline must be accompanied by a separate motion for leave and a proposed order.

Responses that are filed after the response deadline provided for in the rules MUST be accompanied by a separate motion for leave to late file the response with a proposed order.

Document Type

Late Response

Content & Formatting
Proposed Order
Harris:section:40
|Sec4. RESPONSES/REPLIES/OBJECTIONS
Filing RequirementsCivil cases

Checked against the court's document on Oct 3, 2026Mandatory

A filing seeking relief must include a certificate of service, any certificate of conference required by the TRCP, and a proposed order.

File your motion or other document with a certificate of service, (include certificate of conference as required by the TRCP) and a proposed order each time you ask the Court to grant or deny relief.

Document Type

Motion Or Other Document Seeking Relief

Content & Formatting
Certificate Of Service
Certificate Of Conference
Proposed Order
Harris:section:40
|SecFILINGS AND COURTESY COPIES
Filing RequirementsCivil cases

Checked against the court's document on Oct 3, 2026Mandatory

A discovery motion must include the disputed discovery responses as e-filing sub-documents or quote the request and answer verbatim in the motion.

Be sure to submit the discovery response(s) at issue as sub-documents when e-filing, or state verbatim the request and answer in the body of your motion.

Document Type

Discovery Motion

Specific requirements detailed in rule text.
Harris:section:40
|Sec3. MOTIONS—Discovery Motions
Filing RequirementsCivil cases

Checked against the court's document on Oct 3, 2026Mandatory

Non-suits, dismissals, and judgments should be labeled interlocutory or final; interlocutory orders should identify dismissed and remaining parties and claims.

All non-suits, dismissals and judgments should be titled as interlocutory or final. Interlocutory orders should expressly list which parties and claims are being dismissed and which remain, if any.

Document Type

Non Suit Dismissal Or Judgment

Specific requirements detailed in rule text.
Harris:section:40
|Sec9. VOLUNTARY NON-SUITS/DISMISSALS/JUDGMENTS
Filing RequirementsCivil cases

Checked against the court's document on Oct 3, 2026Mandatory

A Rule 106 substituted-service motion must include an affidavit describing address-verification efforts, service attempts, people contacted, and records supporting residence at the address.

All motions for substituted service under Rule 106 must be accompanied by an affidavit that includes the following information: ·Efforts taken to verify that defendant actually lives or works at the subject address; ·Each attempt at service, with date(s) and time(s); ·Identity of persons who were present at the subject address and what was said; and · A printout of some public record or Public Data.com or similar online database confirming that the person to be served actually resides at the address at which service is being attempted. This can also include a statement identifying license plates of cars in the driveway and attaching a printout of license plates registered to the person to be served. Statements by neighbors or by people residing in the abode must include the full name of the person and a description. The idea is to give the court some assurance that the person resides at that address.

Document Type

Rule 106 Substituted Service Motion

Specific requirements detailed in rule text.
Harris:section:40
|Sec3. MOTIONS—H. Substitute Service (Rule 106)
Filing RequirementsCivil cases

Checked against the court's document on Oct 3, 2026Mandatory

File a proposed final judgment before contacting the Clerk for a minor-settlement hearing date.

A proposed Final Judgment must be filed before contacting the Clerk to obtain a hearing date on the minor’s settlement.

Document Type

Minor Settlement Proposed Final Judgment

Content & Formatting
Proposed Order
Harris:section:40
|SecSETTLEMENTS INVOLVING CHILDREN
Filing RequirementsCivil cases

Checked against the court's document on Oct 3, 2026Mandatory

File a request for oral hearing or continuance separately from the response and attach a proposed order.

Please clearly identify your request for an oral hearing or your request to continue the hearing by filing them separately from your response with proposed orders attached.

Document Type

Oral Hearing Or Hearing Continuance Request

Content & Formatting
Proposed Order
Harris:section:40
|Sec7. HEARINGS—D) Submission Docket
Filing RequirementsCivil cases

Checked against the court's document on Oct 3, 2026Mandatory

Every continuance or reset motion must identify its sequence number.

In addition, ALL continuance or reset motions (whether agreed, unopposed or opposed) MUST state what number continuance motion is being filed (i.e. "Plaintiff’s First” or “Defendant’s Second” or “Third Agreed Motion,” etc.).

Document Type

Continuance Or Reset Motion

Specific requirements detailed in rule text.
Harris:section:40
|Sec3. MOTIONS—Agreed Motions
Filing RequirementsCivil cases

Checked against the court's document on Oct 3, 2026Mandatory

A motion to continue a trial or pretrial deadline must include an appropriate affidavit unless the motion is agreed.

Motions for trial or pretrial deadline continuances MUST be accompanied by an appropriate affidavit, unless they are agreed.

Document Type

Trial Or Pretrial Deadline Continuance Motion

Specific requirements detailed in rule text.
Harris:section:40
|Sec3. MOTIONS—I. Trial Continuances
Filing RequirementsCivil cases

Checked against the court's document on Oct 3, 2026Mandatory

Severance motions and orders must include the specified case, party, pleading, attorney, status, finality, and cost information.

All motions and orders for severance must contain the following: ·New case number, court number, case type and new style name; ·Reference the parties in the new suit; ·List of original pleadings to be severed out and transferred to the new case (together with a listing of the document type, activity date for the document, number of pages and image number); ·Indicate attorney name, address and bar number to whom costs for the severance are to be assessed; and ·Indicate the severance case's status, and whether the new case file is interlocutory (not a final appealable matter) or whether severance will cause the newly severed matter to be final and appealable upon severance. As an example, if a plaintiff obtains a summary judgment as to one of multiple defendants and severs the disposed claims against that defendant into a new cause, that severance order will start the appellate timelines because all claims in the new cause will be resolved as to all claims and all parties. This should be expressly stated one way or the other in the motion for severance. Whether the severance order disposes of the severed case or whether the severed case will remain active; and The party responsible for payment of court costs and severance fees.

Document Type

Severance Motion And Order

Specific requirements detailed in rule text.
Harris:section:40
|Sec3. MOTIONS—F. Severances
Filing RequirementsCivil cases

Checked against the court's document on Oct 3, 2026Mandatory

In a non-jury trial, proposed findings of fact and conclusions of law must be filed before trial.

In a non-jury trial, proposed Findings of Fact and Conclusions of Law MUST be filed prior to trial to enable the court to follow along during trial.

Document Type

Proposed Findings And Conclusions

Specific requirements detailed in rule text.
Harris:section:40
|Sec8. TRIALS—E) Findings of Fact/Conclusions of Law
Filing RequirementsCivil cases

Checked against the court's document on Oct 3, 2026Mandatory

Motions must include an explicit certificate of conference describing efforts to resolve the matter with all other parties or counsel before filing, when required by the cited rules.

All motions must have certificates of conference as required by the Texas Rules of Civil Procedure and our local rules. All certificates of conference must be explicit as to the party’s efforts to resolve the motion with all other parties/counsel prior to filing.

Document Type

Motion

Content & Formatting
Certificate Of Conference
Harris:section:40
|Sec5. CERTIFICATES OF CONFERENCE
Filing RequirementsCivil cases

Checked against the court's document on Oct 3, 2026Mandatory

Counsel must verify cited authorities and quotations; relief relying on nonexistent, fabricated, or hallucinated citations will be denied.

Counsel are responsible for ensuring that all cited authorities exist and are accurately quoted. Citations to nonexistent, fabricated, or “hallucinated” cases will not be tolerated. If the Court determines that a motion contains such citations upon which its request for relief relies, the requested relief will be denied without further consideration.

Document Type

Motion

Specific requirements detailed in rule text.
Harris:section:40
|Sec3. MOTIONS—Citations and Hyperlinks
Filing RequirementsCivil cases

Checked against the court's document on Oct 3, 2026Mandatory

A special exception must identify the challenged pleading or portion by page and paragraph, except when it challenges only the maximum damages sought under TRCP 47.

Please explicitly identify by page and paragraph the pleading or portion thereof to which you are specially excepting (unless the special exception is only to the maximum amount of damages sought pursuant to TRCP 47).

Document Type

Special Exception

Specific requirements detailed in rule text.
Harris:section:40
|Sec3. MOTIONS—G. Special Exceptions
Filing RequirementsCivil cases

Checked against the court's document on Oct 3, 2026Mandatory

The Court Clerk will remove noncompliant motions from the docket and notify the requesting party.

The Court Clerk will remove from the docket any motions that do not comply with this rule and will notify the requesting party of the same.

Document Type

Motion

Specific requirements detailed in rule text.
Harris:section:40
|Sec5. CERTIFICATES OF CONFERENCE
Filing RequirementsCivil cases

Checked against the court's document on Oct 3, 2026Mandatory

A summary-judgment motion may be withdrawn only by a written notice bearing the specified title and identifying the original filing date.

To withdraw a motion for summary judgment, the party must file a written notice of withdrawal with the Court. The notice shall be titled “Notice of Withdrawal of Motion for Summary Judgment” and, pursuant to Rule 166a, as amended, must identify the date the motion was originally filed.

Document Type

Summary Judgment Withdrawal Notice

Specific requirements detailed in rule text.
Harris:section:40
|Sec7. HEARINGS—G) Summary Judgments
Filing RequirementsCivil cases

Checked against the court's document on Oct 3, 2026Mandatory

A final order must state that it disposes of all claims and parties and is intended to be final and appealable.

Final orders MUST state that the order disposes of all claims and all parties and is intended to be a final, appealable order.

Document Type

Final Order

Specific requirements detailed in rule text.
Harris:section:40
|Sec9. VOLUNTARY NON-SUITS/DISMISSALS/JUDGMENTS
Filing RequirementsCivil cases

Checked against the court's document on Oct 3, 2026Mandatory

If the defaulting party was served at an address different from the citation address, the movant must seek to amend the citation and include a proposed order.

If the defaulting party was served at an address different from the one listed on the citation, the movant must file a Motion to Amend Citation. This motion should request that the citation be amended to reflect the address where valid service was achieved and should include a proposed Order to Amend Citation.

Document Type

Motion To Amend Citation

Content & Formatting
Proposed Order
Harris:section:40
|Sec3. MOTIONS—D. Default Judgments
Filing RequirementsCivil cases

Checked against the court's document on Oct 3, 2026Mandatory

Requests for attorney’s fees as sanctions must be supported by an affidavit or live testimony establishing reasonableness and necessity, unless the parties agree to the amount in one of the stated ways.

All requests for attorney’s fees as sanctions MUST be established by affidavit (preferred) or live testimony as to reasonableness and necessity (and meet other legal requirements), unless the parties agree on the record, in a filed Rule 11 Agreement, or an agreed order as to the amount.

Document Type

Request For Attorney Fees As Sanctions

Specific requirements detailed in rule text.
Harris:section:40
|Sec3. MOTIONS—E. Sanctions
Filing RequirementsCivil cases

Checked against the court's document on Oct 3, 2026Mandatory

Do not combine multiple motions in one proposed order.

Do not combine multiple motions into a single proposed order.

Document Type

Proposed Order

Specific requirements detailed in rule text.
Harris:section:40
|Sec6. PROPOSED ORDERS
Filing RequirementsCivil cases

Checked against the court's document on Oct 3, 2026Mandatory

Discovery motions and proposed orders must separately identify each disputed issue, request, or objection so the Court can rule item by item.

The motion and proposed order must identify each discovery issue separately. Proposed orders shall list each disputed request or objection individually, allowing the Court to grant or deny relief as to each item.

Document Type

Discovery Motion And Proposed Order

Specific requirements detailed in rule text.
Harris:section:40
|Sec3. MOTIONS—C. Discovery Disputes
Filing RequirementsCivil cases

Checked against the court's document on Oct 3, 2026Mandatory

A default judgment motion seeking attorney’s fees must include an affidavit with competent evidence addressing counsel’s experience, work, time spent, and hourly rate.

When seeking attorney’s fees in a motion for default judgment, the movant must include an affidavit providing competent evidence to support the claim. At a minimum, the affidavit should address: (1) counsel’s experience; (2) the work performed in the case; (3) the time spent performing that work; and (4) the hourly rate charged.

Document Type

Default Judgment Motion For Attorney Fees

Specific requirements detailed in rule text.
Harris:section:40
|Sec3. MOTIONS—D. Default Judgments
Filing RequirementsCivil cases

Checked against the court's document on Oct 3, 2026Important

Counsel citing an unpublished opinion must provide its Westlaw citation.

If citing an unpublished opinion, counsel shall provide the Westlaw citation.

Document Type

Filing Citing Unpublished Opinion

Specific requirements detailed in rule text.
Harris:section:40
|Sec3. MOTIONS—Citations and Hyperlinks
Filing RequirementsCivil cases

Checked against the court's document on Oct 3, 2026Important

If the other side could not be reached before filing, the certificate should describe communication efforts and be supplemented as soon as possible after the parties confer.

If a party was unable to reach the other side prior to filing the motion, the certificate should state the efforts to communicate with that party and should always be supplemented as soon as possible after the parties have actually conferred.

Document Type

Certificate Of Conference

Specific requirements detailed in rule text.
Harris:section:40
|Sec5. CERTIFICATES OF CONFERENCE
Filing RequirementsCivil cases

Checked against the court's document on Oct 3, 2026Important

Dismissals should be filed with prejudice.

All dismissals should be filed with prejudice.

Document Type

Dismissal

Specific requirements detailed in rule text.
Harris:section:40
|Sec9. VOLUNTARY NON-SUITS/DISMISSALS/JUDGMENTS
Filing RequirementsCivil cases

Checked against the court's document on Oct 3, 2026Important

Exhibits should be indexed.

Please index your exhibits.

Document Type

Filing With Exhibits

Content & Formatting
Exhibit List
Harris:section:40
|SecFILINGS AND COURTESY COPIES
Filing RequirementsCivil cases

Checked against the court's document on Oct 3, 2026Important

Proposed orders should identify each discovery issue separately so the Court can rule specifically on each requested item.

Proposed orders should list each discovery issue separately so that the court may sign a specific order granting or denying the requested relief.

Document Type

Discovery Proposed Order

Specific requirements detailed in rule text.
Harris:section:40
|Sec6. PROPOSED ORDERS
Filing RequirementsCivil cases

Checked against the court's document on Oct 3, 2026Important

An agreed motion and order should include signature blocks for all parties agreeing to the relief and the specified agreement language.

If a motion is actually agreed, the motion and order should contain signature blocks for all parties that are agreed to the relief requested and should state “AGREED AS TO SUBSTANCE AND FORM AND ENTRY REQUESTED” above the signature block.

Document Type

Agreed Motion And Order

Specific requirements detailed in rule text.
Harris:section:40
|Sec3. MOTIONS—Agreed Motions
Filing RequirementsCivil cases

Checked against the court's document on Oct 3, 2026Important

Lexis citations are unacceptable unless a copy of the unpublished opinion is provided to the Court.

The Court does not use Lexis; Lexis citations are not acceptable unless a copy of the unpublished opinion is provided to the Court.

Document Type

Filing Citing Unpublished Opinion

Specific requirements detailed in rule text.
Harris:section:40
|Sec3. MOTIONS—Citations and Hyperlinks
Filing RequirementsCivil cases

Checked against the court's document on Oct 3, 2026Important

Motions should be accompanied by an order.

All motions should be accompanied with an Order.

Document Type

Motion

Content & Formatting
Proposed Order
Harris:section:40
|Sec3. MOTIONS—Agreed Motions
Filing RequirementsCivil cases

Checked against the court's document on Oct 3, 2026Important

The first and second agreed continuances should be filed as Rule 11 notices that state the reason for the continuance.

First and second agreed continuances should be filed as a Rule 11 Notice. Please include the reason that you are requesting a continuance as you would in the motion.

Document Type

First Or Second Agreed Continuance

Specific requirements detailed in rule text.
Harris:section:40
|Sec3. MOTIONS—I. Trial Continuances
Filing RequirementsCivil cases

Checked against the court's document on Oct 3, 2026Important

A Rule 106 motion should include the court's form proposed order; omission may delay the ruling.

Any Rule 106 Motion should be accompanied by this form proposed order. Failure to do so may delay the court’s granting of an otherwise proper motion.

Document Type

Rule 106 Motion

Content & Formatting
Proposed Order
Harris:section:40
|Sec3. MOTIONS—H. Substitute Service (Rule 106)
Filing RequirementsCivil cases

Checked against the court's document on Oct 3, 2026Important

Unopposed and agreed motions should be titled accordingly.

All unopposed or agreed motions should be titled as such.

Document Type

Motion

Specific requirements detailed in rule text.
Harris:section:40
|Sec3. MOTIONS—Agreed Motions
Filing RequirementsCivil cases

Checked against the court's document on Oct 3, 2026Important

A proposed order submission must include a cover letter stating whether the order is agreed as to form.

When submitting a proposed order, include a cover letter stating whether the order is agreed as to form.

Document Type

Proposed Order Submission

Specific requirements detailed in rule text.
Harris:section:40
|Sec6. PROPOSED ORDERS
Filing RequirementsCivil cases

Checked against the court's document on Oct 3, 2026Important

Before a temporary injunction hearing, inform the Court whether the parties are ready, whether they were properly served, and the expected hearing length and witness count.

For a temporary injunction hearing, it is imperative that we know whether or not you are ready to proceed; if the parties were properly served, and the length of time and the number of witnesses.

Document Type

Temporary Injunction Hearing Submission

Specific requirements detailed in rule text.
Harris:section:40
|Sec7. HEARINGS—E) Temporary Injunctions
Filing RequirementsCivil cases

Checked against the court's document on Oct 3, 2026Important

Non-suit motions, notices, and orders should expressly state they are filed under Texas Rule of Civil Procedure 162.

Motions and notices of non-suit as well as orders of non-suit should expressly state that they are being filed pursuant toRule 162of the Texas Rules of Civil Procedure.

Document Type

Non Suit Motion Notice Or Order

Specific requirements detailed in rule text.
Harris:section:40
|Sec9. VOLUNTARY NON-SUITS/DISMISSALS/JUDGMENTS
Filing RequirementsCivil cases

Checked against the court's document on Oct 3, 2026Note

Parties are encouraged to quote the challenged paragraphs in the proposed order and provide separate checkboxes for the Court's ruling on each matter.

Parties are encouraged to restate verbatim the paragraph(s) to which your special exceptions apply in the proposed order and provide blanks in which the Court may check "sustained" or "overruled" as to each separate matter to which the movant is specially excepting.

Document Type

Special Exception Proposed Order

Specific requirements detailed in rule text.
Harris:section:40
|Sec3. MOTIONS—G. Special Exceptions
Filing RequirementsCivil cases

Checked against the court's document on Oct 3, 2026Note

The Court prefers the Supreme Court Ad Litem Fee Report to be filed before the hearing, but it is not required to obtain a hearing date.

The Court prefers that the Supreme Court Ad Litem Fee Report be filed in advance of the hearing; however, it is not required in order to obtain a hearing date.

Document Type

Supreme Court Ad Litem Fee Report

Specific requirements detailed in rule text.
Harris:section:40
|SecSETTLEMENTS INVOLVING CHILDREN
Filing RequirementsCivil cases

Not confirmed. Read the court's wording below.Mandatory?

Include an explicit certificate of conference as described in the section of these procedures titled “Certificates of Conference”.

Summary: Discovery motions must include an explicit certificate of conference.

Document Type

Discovery Motion

Content & Formatting
Certificate Of Conference
Harris:section:40
|Sec3. MOTIONS—Discovery Motions
Filing RequirementsCivil cases

Not confirmed. Read the court's wording below.Mandatory?

If you are requesting damages or fees, the Court requires you to provide exhibits to prove up the damages sought.

Summary: A default judgment request for damages or fees must include exhibits proving the requested amounts.

Document Type

Default Judgment Request For Damages Or Fees

Content & Formatting
Exhibit List
Harris:section:40
|Sec3. MOTIONS—D. Default Judgments
Filing RequirementsCivil cases

Not confirmed. Read the court's wording below.Mandatory?

These motions DO require a certificate of conference, as opposing counsel has a right to be heard on these motions.

Summary: Motions to withdraw as attorney of record require a certificate of conference.

Document Type

Motion To Withdraw As Attorney Of Record

Content & Formatting
Certificate Of Conference
Harris:section:40
|Sec3. MOTIONS—J. Withdrawal as Attorney of Record
Filing RequirementsCivil cases

Not confirmed. Read the court's wording below.Mandatory?

If a movant requests an oral hearing, the request must appear in the title of the motion.

Summary: A summary-judgment motion requesting an oral hearing must state that request in its title.

Document Type

Summary Judgment Motion

Specific requirements detailed in rule text.
Harris:section:40
|Sec7. HEARINGS—G) Summary Judgments
Filing RequirementsCivil cases

Not confirmed. Read the court's wording below.Mandatory?

The parties shall file an Agreed Motion and Proposed Order for Appointment of Guardian ad Litem.

Summary: In settlements involving minor children, the parties must file an agreed motion and proposed order appointing a Guardian ad Litem.

Document Type

Minor Settlement Guardian Ad Litem Appointment

Content & Formatting
Proposed Order
Harris:section:40
|SecSETTLEMENTS INVOLVING CHILDREN
Filing RequirementsCivil cases

Not confirmed. Read the court's wording below.Mandatory?

A Certificate of Last Known Address must be filed.

Document Type

Default Judgment Filing

Specific requirements detailed in rule text.
Harris:section:40
|Sec3. MOTIONS—D. Default Judgments
Filing RequirementsCivil cases

Not confirmed. Read the court's wording below.Mandatory?

Provide page/line for any witness anticipated to testify by deposition PRIOR to the docket call.

Summary: Provide page and line references for any witness expected to testify by deposition before docket call.

Document Type

Deposition Designations

Specific requirements detailed in rule text.
Harris:section:40
|Sec8. TRIALS—B) Depositions
Filing RequirementsCivil cases

Not confirmed. Read the court's wording below.Mandatory?

Please make clear in your motion and proposed judgment whether the judgment will be final (disposing of all claims and all parties) or interlocutory (partial).

Summary: A default motion and proposed judgment must state whether the judgment is final or interlocutory.

Document Type

Default Judgment Motion And Proposed Judgment

Specific requirements detailed in rule text.
Harris:section:40
|Sec3. MOTIONS—D. Default Judgments
Filing RequirementsCivil cases

Not confirmed. Read the court's wording below.Important?

The Court may pass any hearing on a motion filed without a proposed order.

Summary: The Court may pass a hearing on a motion filed without a proposed order.

Document Type

Motion

Content & Formatting
Proposed Order
Harris:section:40
|Sec6. PROPOSED ORDERS
Filing RequirementsCivil cases

Not confirmed. Read the court's wording below.Important?

If amendments are made, the parties must either file the amended proposed judgment or present a copy at the hearing with all changes from the previously filed version clearly highlighted.

Summary: If the proposed judgment is amended, file the amended version or bring a hearing copy with all changes clearly highlighted.

Document Type

Amended Minor Settlement Proposed Judgment

Specific requirements detailed in rule text.
Harris:section:40
|SecSETTLEMENTS INVOLVING CHILDREN

Filing & Service rules

Electronic Filing Rules

To pass an oral hearing or submission, use the e-Hearing system and/or e-file a notice identifying the setting's time, date, and motion.

If you wish to pass an oral hearing or submission setting. Pass the setting on the e-Hearing system and/or efile a Notice to Pass the hearing. Specify the time, date and motion to be discussed.

Checked against the court's document on Oct 3, 2026 · Civil cases

Page 1 | TO PASS A HEARING (SUBMISSION/ORAL)

Documents must be filed electronically through efiletexas.gov, subject to exceptions permitted by the Texas Supreme Court's e-filing rules.

All documents shall be filed electronically through efiletexas.gov except as permitted by the Texas Supreme Court's e-filing rules effective January 1, 2014.

Checked and corrected to match the court's document on Oct 3, 2026 · Civil cases

Page 1 | FILINGS AND COURTESY COPIES

If only one side considers the matter an emergency, file a motion for emergency hearing.

If only one side thinks it is an emergency, efile a motion for emergency hearing.

Checked against the court's document on Oct 3, 2026 · Civil cases

Page 1 | 7. HEARINGS—B) Emergencies

After assignment to trial, parties should email the Trial Coordinator their proposed charge in Microsoft Word format.

Only when actually assigned to trial, the parties should email the Trial Coordinator their proposed charge to the court in Microsoft Word format so that the court may compile the court’s charge as the trial proceeds.

Checked against the court's document on Oct 3, 2026 · Civil cases

Page 1 | 8. TRIALS—D) Court’s Charge

Parties need not appear in person to announce settlement if an e-filed Notice of Settlement is on file.

Parties are not required to appear in person to announce a settlement if a Notice of Settlement is on file (efiled).

Checked against the court's document on Oct 3, 2026 · Civil cases

Page 1 | SETTLEMENT ANNOUNCEMENTS

The Court may require longer or more complex proposed orders to be emailed to the Clerk in Word format.

In some instances, the Court may require that longer or more complex proposed orders be emailed to the Clerk in Word format.

Checked against the court's document on Oct 3, 2026 · Civil cases

Page 1 | 6. PROPOSED ORDERS

Filing Timing and Cure Windows

File the appointee fee and proposed final judgment 24 hours before the hearing.

Please ensure the appointee fee and proposed final judgment are filed 24 hours prior to the hearing.

Checked against the court's document on Oct 3, 2026 · Civil cases

Page 1 | 7. HEARINGS—F) Minor Settlements

Present disputed jury-questionnaire questions to Judge Hughes by submission or oral hearing before docket call.

If there are any questions not agreed on, you need to present them to Judge Hughes by submission or oral hearing PRIOR to the docket call.

Checked against the court's document on Oct 3, 2026 · Civil cases

Page 1 | 8. TRIALS—H) Voir Dire

A matter set for oral hearing after the DCO deadline will not be considered without a motion for leave explaining sufficient cause for late filing.

PLEASE NOTE: Any matter that has been set by the parties for an oral hearing on a date later than the deadline in the DCO will not be considered by the court without a motion for leave explaining sufficient cause for the late filing.

Checked against the court's document on Oct 3, 2026 · Civil cases

Page 1 | 7. HEARINGS—C) Law Day Docket

Necessary replies and sur-replies for a Monday hearing should be filed by the preceding Thursday.

Please do everything in your power to file any necessary replies (or sur-replies, etc.) by Thursday before a Monday hearing.

Checked against the court's document on Oct 3, 2026 · Civil cases

Page 1 | 4. RESPONSES/REPLIES/OBJECTIONS

Continuance motions should be filed early.

Continuance motions should be filed early.

Checked against the court's document on Oct 3, 2026 · Civil cases

Page 1 | 3. MOTIONS—I. Trial Continuances

Motions to exclude experts should be filed and set for hearing well before trial.

All motions to exclude experts should be filed AND set for hearing WELL IN ADVANCE OF TRIAL.

Checked against the court's document on Oct 3, 2026 · Civil cases

Page 1 | 3. MOTIONS—K. Daubert Motions

Replies filed after noon Friday for a Monday oral hearing are unlikely to be considered.

Any replies that are filed after Friday at NOON for a Monday oral hearing are NOT LIKELY to be considered by the Court.

Checked against the court's document on Oct 3, 2026 · Civil cases

Page 1 | 4. RESPONSES/REPLIES/OBJECTIONS

If deposition objections remain, the party seeking exclusion should promptly file a motion for a ruling before voir dire.

If objections remain, then the party seeking to exclude the testimony should file a motion to rule on the objections as soon as possible so that the court can promptly rule on the objections prior to voir dire.

Checked against the court's document on Oct 3, 2026 · Civil cases

Page 1 | 8. TRIALS—B) Depositions

A final judgment or other dispositive filing should be submitted within 14 days after notice of settlement or the case may be dismissed, subject to possible extension.

If a final judgment or other dispositive efiling is not submitted within fourteen (14) days after the Court is notified of the settlement, the case may be dismissed for want of prosecution. The Court may extend this deadline if appropriate.

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

Page 1 | SETTLEMENT ANNOUNCEMENTS

An expert-exclusion motion filed after the docket-control-order deadline will not be considered absent a motion for leave showing exceptionally good cause.

The court will NOT consider such motions filed after the deadline in the docket control order without a motion for leave demonstrating exceptionally good cause.

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

Page 1 | 3. MOTIONS—K. Daubert Motions

Service and Proof of Service Rules

The movant must give defaulting parties and other appearing parties 10 days’ notice of the hearing and motion by regular and certified mail, and certify service.

The Court requires the movant to provide defaulting parties, as well as any other parties who have appeared in the case, with 10 days’ notice of the hearing and the default motion. Notice must be sent via regular and certified mail, and the movant must certify this action in a certificate of service.

Checked against the court's document on Oct 3, 2026 · Civil cases

Page 1 | 3. MOTIONS—D. Default Judgments

The submission docket is Monday at 8:00 a.m. and requires 10 days’ notice.

Submission docket is on Monday at 8:00 AM after 10 days’ notice.

Checked against the court's document on Oct 3, 2026 · Civil cases

Page 1 | 7. HEARINGS—D) Submission Docket

The movant must give all parties proper notice if an emergency hearing is granted.

If an emergency hearing is granted, the movant is responsible for providing proper notice of the hearing to all parties.

Checked against the court's document on Oct 3, 2026 · Civil cases

Page 1 | 7. HEARINGS—B) Emergencies

The movant must provide proper written hearing notice to the Court and all parties.

It is the movant’s responsibility to provide proper written notice of the hearing to the Court and to all parties.

Checked and corrected to match the court's document on Oct 3, 2026 · Civil cases

Page 1 | 7. HEARINGS—C) Law Day Docket

After obtaining a hearing date through e-Hearing, file a notice of oral hearing and serve all counsel and self-represented litigants.

Once you obtain a hearing date from the e-Hearing system, file a notice of oral hearing and serve it on all counsels and/or pro se litigants.

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

Page 1 | 7. HEARINGS—C) Law Day Docket

Most oral hearings require 10 days’ notice to opposing counsel unless all parties agree to shorten the notice period.

For most motions, the court requires 10 days’ notice to opposing counsel for an oral hearing, unless shortened by agreement of all parties.

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

Page 1 | 7. HEARINGS—C) Law Day Docket

Courtesy Copy Requirements

The Court does not accept paper or emailed courtesy copies.

The Court no longer accepts paper courtesy copies or e-mails of courtesy copies.

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

Page 1 | FILINGS AND COURTESY COPIES

Do not serve paper copies of mandamus petitions on the Court; deliver them on a flash drive or disc.

COPIES OF MANDAMUS PETITIONS: Please do not serve the Court with paper copies of your mandamus petition. Please put it on a flash drive or disc and deliver it to the Court.

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

Page 1 | FILINGS AND COURTESY COPIES

If a courtesy copy is necessary despite being discouraged, provide it on a flash drive or disc.

Alternatively, if you absolutely must file a courtesy copy of the document (which is discouraged) then you must do so on a flash drive or disc.

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

Page 1 | FILINGS AND COURTESY COPIES

Courtesy copies of proposed findings and conclusions should be emailed to the Trial Coordinator in Microsoft Word format.

Courtesy copies should be filed via e-mail to the Trial Coordinator in Microsoft Word format.

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

Page 1 | 8. TRIALS—E) Findings of Fact/Conclusions of Law

For a motion containing hyperlinks, counsel may provide it on a USB thumb drive together with any required courtesy copies.

If a motion contains hyperlinks, counsel may provide a courtesy copy of the motion on a USB thumb drive with any required courtesy copies.

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

Page 1 | 3. MOTIONS—Citations and Hyperlinks

Filing Bundling Requirements

Before docket call, parties must exchange proposed jury charges, motions in limine, exhibit lists and exhibits, party/attorney and witness lists, and deposition excerpts.

This court requires the parties to actually exchange proposed jury charges, motions in limine, exhibit lists, actual exhibits, party/attorney lists, witness lists, and deposition excerpts BEFORE the docket call, which is usually conducted by the coordinator via email the Friday that is 10 days before the beginning of the two-week trial docket.

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

Page 1 | 8. TRIALS—A) Pretrial Orders/Exhibits/Motions in Limine

Parties should eliminate duplicate exhibits by agreement where possible.

Eliminate duplicate exhibits, if possible, by agreement.

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

Page 1 | 8. TRIALS—A) Pretrial Orders/Exhibits/Motions in Limine

Pre-Motion Conference Requirements

Default judgment motions based on unpaid assessments or deed restriction violations must be set for oral hearing.

Motions for Default Judgment based on unpaid assessments or deed restriction violations must be set for oral hearing.

Checked against the court's document on Oct 3, 2026 · Civil cases

Page 1 | Special Note Regarding Homeowners’ Association Defaults

Default judgments are set on submission unless unliquidated damages must be proved.

Default judgments are set on the submission docket unless you need to prove up unliquidated damages.

Checked against the court's document on Oct 3, 2026 · Civil cases

Page 1 | 3. MOTIONS—D. Default Judgments

If form objections in a deposition transcript cannot be resolved by agreement, the party seeking to overrule them should file a motion for a ruling.

Separately, if there are “form” objections in the deposition transcript that cannot be agreed upon, the party seeking to overrule the objection should file a motion for a ruling on these.

Checked against the court's document on Oct 3, 2026 · Civil cases

Page 1 | 8. TRIALS—B) Depositions

The listed motions are ordinarily decided on submission, although the Court may require an oral or telephone hearing in some circumstances.

The Court requires that certain motions be considered only on submission. These motions include; liquidated default judgment motions (unliquidated damages motions for default will, of course, require an oral hearing with a record), motions to compel, objections to discovery, motions to reinstate, motions to enroll pro hac vice, routine Rule 47 special exceptions, motions to withdraw as attorney of record, motion to substitute counsel, motion to appoint ad litems, referral and objections to mediation, motion to deposit registry funds, and motions for withdrawal of funds. HOWEVER, the court, in its' discretion, may require an oral hearing or phone conference hearing for such motions in certain circumstances.

Checked against the court's document on Oct 3, 2026 · Civil cases

Page 1 | 7. HEARINGS—D) Submission Docket

Sanctions are infrequently awarded unless the opponent violated a previous order or engaged in egregious conduct.

Sanctions will infrequently be awarded unless the opponent has violated a previous order or the conduct is egregious.

Checked against the court's document on Oct 3, 2026 · Civil cases

Page 1 | 3. MOTIONS—E. Sanctions

Agreed or unopposed motions need not be set for oral hearing or submission unless the judge directs otherwise.

Agreed or unopposed motions do not have to be placed on the court’s oral hearing or submission docket, unless otherwise stated by Judge Hughes.

Checked against the court's document on Oct 3, 2026 · Civil cases

Page 1 | 3. MOTIONS—Agreed Motions

Parties must consult with each other about an emergency hearing matter, preferably through lead counsel.

Parties must consult with each other about the matter (preferably lead attorney on the case to opposing lead attorney on the case).

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

Page 1 | 7. HEARINGS—B) Emergencies

Parties should confer before filing any discovery-related motion.

Always consult with each other (preferably lead attorney on the case to opposing lead attorney on the case) before filing any motions related to discovery.

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

Page 1 | 3. MOTIONS—Discovery Motions

Parties should make reasonable efforts to resolve discovery disputes before seeking judicial intervention; unresolved disputes may be presented by motion to compel for hearing or submission.

The Court expects parties to make every reasonable effort to resolve discovery disputes without judicial intervention. If those efforts are unsuccessful, a party may file a motion to compel and either set the matter for oral hearing or set it for submission, as appropriate.

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

Page 1 | 3. MOTIONS—C. Discovery Disputes

A summary-judgment motion without an oral-hearing request in its title will be placed on the submission docket.

If the request for oral hearing does not appear in the title of the motion, the motion will be placed on the Court’s submission docket.

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

Page 1 | 7. HEARINGS—G) Summary Judgments

Adjournment & Extension Requirements

A summary-judgment motion cannot be passed; the party must proceed or withdraw, and any reset request must comply with Rule 166a and be authorized by it.

Passing a motion for summary judgment is not permitted under Rule 166a, as amended. A party must either proceed on the motion or withdraw it. Any request to reset the hearing or submission must strictly comply with Rule 166a and will be granted only if authorized by the rule.

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

Page 1 | 7. HEARINGS—G) Summary Judgments

Chambers Communication Rules

For a jury panel larger than 60, notify the trial coordinator at least 45 days before trial.

If you need a panel larger than 60, please advise the trial coordinator at least 45 days before trial so that we may reserve the ceremonial courtroom.

Checked against the court's document on Oct 3, 2026 · Civil cases

Page 1 | 8. TRIALS—G) Jury Panel

Telephone or email notification to the Court Coordinator alone is insufficient to announce settlement.

Notification by telephone or email to the Court Coordinator is not sufficient.

Checked against the court's document on Oct 3, 2026 · Civil cases

Page 1 | SETTLEMENT ANNOUNCEMENTS

Notify the court coordinator 30 days before trial if using a jury questionnaire.

If you are going to use a jury questionnaire, let the court coordinator know 30 days before trial.

Checked against the court's document on Oct 3, 2026 · Civil cases

Page 1 | 8. TRIALS—H) Voir Dire

If time is short and e-filing is impractical, contact the Court Clerk for instructions.

If time is short and e-filing is impractical, please contact the Court Clerk for further instructions.

Checked and corrected to match the court's document on Oct 3, 2026 · Civil cases

Page 1 | 7. HEARINGS—B) Emergencies

After passing a hearing, the requestor must promptly notify the Court Clerk and all parties.

If a hearing is passed, the requestor must promptly notify the Court Clerk at 832-927-2450 and all parties.

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

Page 1 | TO PASS A HEARING (SUBMISSION/ORAL)

An email or telephone call to the Clerk does not withdraw a summary-judgment motion.

An email to, or telephone call with, the Clerk advising of an intent to withdraw the motion is insufficient and does not constitute withdrawal or compliance with Rule 166a.

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

Page 1 | 7. HEARINGS—G) Summary Judgments

The movant must timely notify opposing counsel when passing a hearing.

It is also the movant’s responsibility to timely advise opposing counsel if he/she is passing the hearing.

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

Page 1 | 7. HEARINGS—C) Law Day Docket

If both sides agree that a matter is an emergency, call the Court Clerk to arrange a conference with Judge Hughes.

If both sides agree to an emergency hearing, call the Court Clerk to set up a conference by Zoom, phone or in person with Judge Hughes.

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

Page 1 | 7. HEARINGS—B) Emergencies

Opposing counsel must promptly advise of any objections to deposition testimony designations.

Opposing counsel must promptly advise of any objections.

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

Page 1 | 8. TRIALS—B) Depositions

To bring a filing to the Court's attention, file it electronically and then call the Court to ask it to review the filing.

Instead, if a party wishes to bring a particular filing to the Court's attention, the party may (1) file the document electronically with the clerk's office as it normally does and then (2) call the Court to bring the document to the Court's attention, and ask the Court to view and consider the document that is already in the Court's electronic file system.

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

Page 1 | FILINGS AND COURTESY COPIES

About Judge Erica R. Hughes

Judge Erica R. Hughes is a district judge in the Harris County District Courts, which hear civil matters in the Houston metropolitan area.

Judge Hughes's procedures are published through the court's general rules.

Common questions about Judge Erica R. Hughes's rules

Are courtesy copies required for Judge Erica R. Hughes?

The Court does not accept paper or emailed courtesy copies.

View ruleSource: page 1, section FILINGS AND COURTESY COPIES

Does Judge Erica R. Hughes require a pre-motion conference or letter before filing a motion?

Judge Erica R. Hughes's rules set a pre-motion procedure for discovery. Parties should confer before filing any discovery-related motion.

View ruleSource: page 1, section 3. MOTIONS—Discovery Motions

What formatting rules apply to filings before Judge Erica R. Hughes?

Judge Erica R. Hughes' formatting rule includes letter paper and mark an 8 x 11 size exhibit for any blowup used.. Prepare an 8-by-11-inch exhibit for any blowup used.

View ruleSource: page 1, section 8. TRIALS—A) Pretrial Orders/Exhibits/Motions in Limine

What must be included with motion or other document seeking relief filings before Judge Erica R. Hughes?

The rule requires proposed order, certificate of service, and certificate of conference. A filing seeking relief must include a certificate of service, any certificate of conference required by the TRCP, and a proposed order.

View ruleSource: page 1, section FILINGS AND COURTESY COPIES

What must be included with motion to withdraw as attorney of record filings before Judge Erica R. Hughes?

The rule requires certificate of conference. Motions to withdraw as attorney of record require a certificate of conference.

View ruleSource: page 1, section 3. MOTIONS—J. Withdrawal as Attorney of Record

How may parties contact Judge Erica R. Hughes' chambers?

The rule addresses phone communications with Judge Erica R. Hughes' clerk. The rule lists phone 832-927-2450. After passing a hearing, the requestor must promptly notify the Court Clerk and all parties.

View ruleSource: page 1, section TO PASS A HEARING (SUBMISSION/ORAL)

How do I request an adjournment or extension before Judge Erica R. Hughes?

Advance notice is not fully stated in the structured details. The request must include reason for request. A summary-judgment motion cannot be passed; the party must proceed or withdraw, and any reset request must comply with Rule 166a and be authorized by it.

View ruleSource: page 1, section 7. HEARINGS—G) Summary Judgments

Does Judge Erica R. Hughes require motion papers to be bundled?

Yes. Judge Erica R. Hughes requires bundling for covered papers. Before docket call, parties must exchange proposed jury charges, motions in limine, exhibit lists and exhibits, party/attorney and witness lists, and deposition excerpts.

View ruleSource: page 1, section 8. TRIALS—A) Pretrial Orders/Exhibits/Motions in Limine

Is electronic filing required before Judge Erica R. Hughes?

Yes. Electronic filing is required for the covered filings. Documents must be filed electronically through efiletexas.gov, subject to exceptions permitted by the Texas Supreme Court's e-filing rules.

View ruleSource: page 1, section FILINGS AND COURTESY COPIES

What filing deadlines does Judge Erica R. Hughes set?

An expert-exclusion motion filed after the docket-control-order deadline will not be considered absent a motion for leave showing exceptionally good cause.

View ruleSource: page 1, section 3. MOTIONS—K. Daubert Motions

What rule applies to service by mail for all parties before Judge Erica R. Hughes?

Proof of service is required for the covered service rule. Details: method: service by mail, recipient: all parties, timing: 10 calendar days before hearing. The movant must give defaulting parties and other appearing parties 10 days’ notice of the hearing and motion by regular and certified mail, and certify service.

View ruleSource: page 1, section 3. MOTIONS—D. Default Judgments
Complete rules summary for Judge Erica R. Hughes

Documents must be filed electronically through efiletexas.gov, subject to exceptions permitted by the Texas Supreme Court's e-filing rules.

A filing seeking relief must include a certificate of service, any certificate of conference required by the TRCP, and a proposed order.

Exhibits should be indexed.

The first and second agreed continuances should be filed as Rule 11 notices that state the reason for the continuance.

Motions to withdraw as attorney of record require a certificate of conference.

The Court does not accept paper or emailed courtesy copies.

To bring a filing to the Court's attention, file it electronically and then call the Court to ask it to review the filing.

If a courtesy copy is necessary despite being discouraged, provide it on a flash drive or disc.

Do not serve paper copies of mandamus petitions on the Court; deliver them on a flash drive or disc.

Counsel must wear business attire at all hearings, including hearings by Zoom, and men must wear a tie.

Motions should be accompanied by an order.

Agreed or unopposed motions need not be set for oral hearing or submission unless the judge directs otherwise.

Unopposed and agreed motions should be titled accordingly.

Every continuance or reset motion must identify its sequence number.

An agreed motion and order should include signature blocks for all parties agreeing to the relief and the specified agreement language.

Parties should confer before filing any discovery-related motion.

Discovery motions must include an explicit certificate of conference.

A discovery motion must include the disputed discovery responses as e-filing sub-documents or quote the request and answer verbatim in the motion.

Motions to exclude experts should be filed and set for hearing well before trial.

Parties should make reasonable efforts to resolve discovery disputes before seeking judicial intervention; unresolved disputes may be presented by motion to compel for hearing or submission.

Discovery motions and proposed orders must separately identify each disputed issue, request, or objection so the Court can rule item by item.

Default judgments are set on submission unless unliquidated damages must be proved.

A default motion and proposed judgment must state whether the judgment is final or interlocutory.

A Certificate of Last Known Address must be filed.

If the defaulting party was served at an address different from the citation address, the movant must seek to amend the citation and include a proposed order.

A default judgment request for damages or fees must include exhibits proving the requested amounts.

A default judgment motion seeking attorney’s fees must include an affidavit with competent evidence addressing counsel’s experience, work, time spent, and hourly rate.

The movant must give defaulting parties and other appearing parties 10 days’ notice of the hearing and motion by regular and certified mail, and certify service.

Default judgment motions based on unpaid assessments or deed restriction violations must be set for oral hearing.

Sanctions are infrequently awarded unless the opponent violated a previous order or engaged in egregious conduct.

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