Harris County District Courts Filing Rules

A severance motion and order must state the new case number, court number, case type, and style name.

Counsel citing an unpublished opinion must provide its Westlaw citation.

Lexis citations are unacceptable unless counsel provides the Court a copy of the unpublished opinion.

Rule 106 motions must be set on the submission docket and include an affidavit with specified information about service attempts and address verification.

Certain listed motions are presented to the Judge upon filing without an oral hearing; all other motions must be set for an oral or submission hearing.

Call the clerk to request an expedited hearing.

A party passing a hearing must notify all parties involved and the court.

Contact the Court Clerk at 832-927-2680 for inquiries about hearings, signed orders, or rulings.

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

Emailing or calling the Clerk to announce an intent to withdraw does not withdraw a summary judgment motion or satisfy Rule 166a.

All summary judgments should be set and heard at least thirty days before trial.

An MSJ set for oral hearing must be set between the 35th and 60th day after the motion is filed.

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

All expert witness challenge motions must be set for hearing before the trial date.

If no final judgment or other dispositive filing is submitted within 14 days after settlement notice, the case may be dismissed for want of prosecution.

A motion will not be set for oral hearing without an estimated hearing time.

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

Motions to withdraw as counsel must be set for oral hearing unless the client agrees and signs an acceptance of the notice letter.

Agreed or unopposed motions, including unopposed continuance motions, are presented expeditiously without a hearing.

The motion must be filed before setting a 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.

The movant must give defaulting parties and all other parties who appeared 10 days’ notice of the hearing and motion.

Notice of oral hearing must be served on all counsel and self-represented parties.

The party requesting an oral hearing must file and serve a notice of oral hearing on all counsel and self-represented parties.

If an emergency hearing is granted, the movant must provide proper notice of the hearing to all parties.

All oral hearings are in-person only.

The Court may require modified orders to be submitted in Word format to the court clerk.

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

For trial exhibits referencing depositions, provide a condensed version of the full deposition.

Any exhibit with more than one page must be stapled, binder clipped, or contained in a notebook.

A request to reset a summary judgment hearing or submission must strictly comply with Rule 166a and will be granted only when that rule authorizes it.

Continuance requests, even agreed ones, are not expected to be granted without good reasons.

Agreed/unopposed continuances in cases older than 2 years must be set for an oral hearing.

First continuances require a showing of good cause and substantial need for delaying the trial setting.

No continuances will be granted to move from a preferential setting except for death or serious illness of a party/lead counsel or an immediate family member; witness unavailability is not grounds for a continuance.

Oral hearing requests for the motion docket must be made through the E-Hearing Portal.

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.

Responses to motions must be e-filed at least 24 hours before the hearing and include a proposed order.

Emergency hearing requests must be e-filed as an emergency motion with a detailed explanation of necessity.

It is preferable to file documents electronically for emergency filings; if time is short and e-filing is impractical, contact the court clerk for instructions.

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

After e-filing pleadings and exhibits for trial, parties must provide two courtesy copies to the Court and written notice to all parties.

When filing a motion for an emergency hearing, a courtesy copy must be sent directly to the Clerk.

A courtesy copy must include the proposed order, latest live pleading and answer, current Docket Control Order, and cited unpublished authority.

The Court does not accept paper or emailed courtesy copies.

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

The parties are asked to eliminate duplicate exhibits by agreement when possible.

Each motion must have its own proposed order; multiple motions should not be combined into one order.

Motions, responses, replies, exhibits, and proposed orders must each be filed as stand-alone documents, though they may be filed in the same envelope.

Do not split your documents into separate envelopes when filing.

Exhibits should be redacted before being offered; exhibits redacted after admission are marked as 'A' exhibits with the unredacted original kept by the court reporter, and any offered exhibit must be tendered to the court reporter.

Parties seeking to seal court records must comply with Texas Rule of Civil Procedure 76a.

Confidential information (such as reasons for withdrawal) may be filed under seal.

Confidential matters included in a motion to withdraw may be filed under seal.

Confidential matters in withdrawal motions may be filed under seal.

Motions expected to last more than 30 minutes should be set by special setting.

Emergency hearing requests must be made to the Court Clerk, with a filed and served letter or motion (max 2 pages) stating reasons for the hearing and emergency.

The Court encourages opportunities for lawyers practicing less than 4 years to participate in hearings or trials, especially when they drafted the underlying motion.