Harris County District Courts Document Filing Requirements

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Motion

Must include

certificate of conference

Certificate of conference required for motions, pleas, and special exceptions except summary judgment, default judgments, voluntary dismissal/non-suit, and service of citations motions.

A certificate of conference is required for all motions (including discovery motions), pleas, and special exceptions except for: motions for summary judgment; default judgments; motions for voluntary dismissal or non-suit; and motions involving service of citations. Certificates of conference must state how and when parties have conferred on the matters on which relief is sought, and whether the relief is opposed, agreed, or agreed in part. For all motions which a certification of conference is required, the Court reserves the right to deny all motions that do not have a certificate of conference.

Checked and corrected to match the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Motion

Must include

proposed order

All motions and responses must include a proposed order with exact motion title, and each motion must have its own order.

All motions and responses must have a proposed order. The Court may pass hearings on motions filed without a proposed order. All motions should have their own proposed order (Please do not combine multiple motions into one order). The proposed order should include the exact title of the motion being considered. Do not title the order submitted as “proposed”.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Discovery motion

Must include

certificate of conference

Discovery motion must include description of dispute, certificate of conference with details, and copy of discovery requests/responses.

The complaining party should file a motion containing: a brief description of the dispute; a certificate of conference stating the name of all counsel participating in the discussions, including the date, time, and place the parties have had out of-court discovery discussions, and the results of those discussions; and a copy or verbatim reproduction of the discovery requests and responses at issue.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Default judgment

Must include

proposed order

Default judgments require oral hearing and filing of notice of hearing, Non-Military Affidavit, certificate of last known address, citation/receipt of service, and proposed final judgment order.

An oral hearing is required on all default judgments. For default judgments, Parties must file a notice of an oral hearing, a Non-Military Affidavit compliant with the Soldiers and Sailors Relief Act, a certificate of last known address, a citation/receipt of service, and a proposed final judgment order.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Motion to withdraw

Motion to withdraw must be set on oral hearing/submission docket and contain specific information and documents.

Motions for withdrawal of counsel must be set on the oral hearing/submission docket. The motion must contain: a statement of the particular circumstances and disciplinary rules requiring withdrawal; a certificate of the attorney of record of the client’s name, address, telephone number, and the last known time the information was correct; a copy of a letter from the attorney of record to the client giving notice: (a) that the attorney is withdrawing; (b) that the client is deemed to have knowledge of and is required to abide by the Texas Rules of Civil Procedure if the client proceeds pro se; (c) that all notices from the Court to the client's current address will be deemed to have been received unless the client notifies the Court of any change of address; (d) that no continuances or extensions will be granted to the pro se client in order to obtain other counsel; and (e) notice of the hearing at which the motion to withdraw will be considered; and a signed acceptance of the terms of the letter described above, if the client has agreed to the withdrawal. If the client has not agreed to the withdrawal, proof of service of the letter described above must be filed.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Notice of oral hearing

Party requesting oral hearing must file notice of hearing stating exact motion titles and serve on all parties.

Once the clerk assigns a hearing date the party requesting the hearing must file a notice of oral hearing and serve it on all counsel and self-represented parties. The hearing notice must state the exact title of the motion or motions to be heard.

Checked and corrected to match the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Trial notebook

Parties must prepare and bring a Trial Notebook with specified contents to pretrial conference.

parties must prepare, exchange and bring to the pretrial conference, one Trial Notebook that contains: · live pleadings; · witness lists (with estimated time for examination and cross-examination of each); · exhibit lists (including copies of exhibits and any objections); · motions in limine and objections; · deposition extracts and objections; and · proposed jury charges.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Motion

Must include

certificate of conference

A certificate of conference is required for all motions, pleas, and special exceptions, with listed exceptions.

A certificate of conference is required for all motions (including discovery motions), pleas, and special exceptions except for: motions for summary judgment; default judgments; motions for voluntary dismissal or non-suit; and motions involving service of citations.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Discovery motion

Must include

certificate of conference

Discovery motion must include a brief description, a detailed certificate of conference, and a copy or verbatim reproduction of discovery requests/responses.

The complaining party should file a motion containing: a brief description of the dispute; a certificate of conference stating the name of all counsel participating in the discussions, including the date, time, and place the parties have had out of-court discovery discussions, and the results of those discussions; and a copy or verbatim reproduction of the discovery requests and responses at issue.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Non military affidavit

The Non-Military Affidavit must comply with recent amendments to the Soldiers and Sailors Relief Act.

The Non-Military Affidavit must comply with recent amendments to the Soldiers and Sailors Relief Act.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Motion to withdraw

A motion to withdraw must contain the specific circumstances, certificate of client information, notice letter with specified advisements, and signed acceptance or proof of service.

However, the motion must contain: a statement of the particular circumstances and disciplinary rules requiring withdrawal; a certificate of the attorney of record of the client’s name, address, telephone number, and the last known time the information was correct; a copy of a letter from the attorney of record to the client giving notice: (a) that the attorney is withdrawing; (b) that the client is deemed to have knowledge of and is required to abide by the Texas Rules of Civil Procedure if the client proceeds pro se; (c) that all notices from the Court to the client's current address will be deemed to have been received unless the client notifies the Court of any change of address; (d) that no continuances or extensions will be granted to the pro se client in order to obtain other counsel; and (e) notice of the hearing at which the motion to withdraw will be considered; and a signed acceptance of the terms of the letter described above, if the client has agreed to the withdrawal. If the client has not agreed to the withdrawal, proof of service of the letter described above must be filed.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Rule 106 motion

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

Rule 106 Motions must be placed on our submission docket and 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 and time; identity of persons who were present at the subject address and what was said; and identity of cars in driveway or other indications that defendant resides at the subject address.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Notice of submission

When setting a matter on the submission docket, file a notice of submission with the exact motion title and serve it on all counsel and self-represented parties.

If you set a matter on the submission docket file a notice of submission with the exact title of the motion set for consideration and serve it on all counsel and self-represented parties.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Continuance order

Must include

proposed order

Proposed continuance orders must be agreed to by all parties; if not, reasons for non-agreement must be stated with specificity.

Proposed continuance orders must be agreed to by all parties. If parties cannot agree to a proposed order, the reasons for non-agreement should be stated with specificity.

Checked against the court's document on Sep 20, 2026CRITICAL

Applies to

Motion

Must include

proposed order

All motions and responses must include a proposed order.

All motions and responses must include a proposed order.

Checked against the court's document on Sep 20, 2026CRITICAL

Applies to

Certificate

Must include

certificate of conference

The Certificate of Conference must state the dates and methods of contact, and should describe efforts to communicate if the other side was not reached.

The Certificate of Conference must contain the dates and methods by which contact was made. 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 including the date and means.

Checked against the court's document on Sep 20, 2026CRITICAL

Applies to

Discovery motion

Discovery motions must attach a copy of the discovery response at issue or state verbatim the request and answer in the body of the motion.

Attach a copy of the discovery response at issue or state verbatim the request and answer in the body of your motion.

Checked against the court's document on Sep 20, 2026CRITICAL

Applies to

Motion

Motions for substituted service under Rule 106 must be accompanied by an affidavit containing the specified verification and attempt details.

All Motions for Substituted Service under Rule 106 must be accompanied by an affidavit that: Describes the efforts taken to verify that the Defendant actually lives or works at the subject address; Shows at least four attempts of service at different times of day with the specific dates and times; Details regarding the identity of the person/people present at the subject address and state what was said; Provide the identity of the owners of any vehicles in the driveway; and Include any other information or indications that the Defendant resides at the subject address.

Checked against the court's document on Sep 20, 2026CRITICAL

Applies to

Proposed order

The order for severance must include the documents to be included in the severed case.

The order for severance must include the documents to be included in the severed case.

Checked against the court's document on Sep 20, 2026CRITICAL

Applies to

Motion

Motions to withdraw leaving a party pro se must include the party's contact information, a consultation statement, and current deadlines and trial settings.

Motions in which party will be pro se after the attorney withdraws must include: the party's telephone number; the party's address; the party's email address; a statement regarding consultation with the party regarding the motion; and current deadlines and trial settings.

Checked against the court's document on Sep 20, 2026CRITICAL

Applies to

Motion

Must include

certificate of service, certificate of conference

A motion to substitute counsel must indicate whether the replaced attorney agreed to the substitution and must include the appropriate certificates of conference and service.

Motion to substitute counsel must indicate whether the attorney being replaced has agreed to the substitution and must have the appropriate certificates of conference and service.

Checked and corrected to match the court's document on Sep 20, 2026CRITICAL

Applies to

Motion

Motions requesting attorney's fees require, in addition to the attorney affidavit, an itemization of work showing date, work performed, time expended per task, and billable rate.

Motions that request attorneys fees will require, in addition to the attorney affidavit, an itemization of the work done including: i. the date the work was performed; ii. the work that was performed; iii. the amount of time expended for each task; and iv. the billable

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Order

If agreeing to a summer Monday, the order must include vacation waiver language and be signed by all counsel and pro se parties.

You can agree to any Monday of your choice, if you choose a Monday in the summer months of June, July or August, you must include the language on the order, that everyone agrees to waive their vacation for that two week period, the order needs to be signed by all counsel and prose parties if any in your case.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Notice of oral hearing

Zoom hearings are limited to 15-minute increments total; movants must include this statement in the Notice of Oral Hearing.

All zoom hearings will be heard in 15 minute increments--total. Movants are to include this in the Notice of Oral Hearing.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Discovery motion

Must include

proposed order

Discovery motions must include a proposed order enumerating each disputed request/response with a Sustained/Overruled line.

With all discovery motions, parties MUST submit a proposed Order, enumerating each discovery request/response in dispute. Next to each discovery request/dispute should be the words: “_____Sustained _____ Overruled”.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Motion

Must include

proposed order

All motions must be accompanied by a proposed order filed at least 48 hours before submission or oral hearing.

You must file a proposed order with your motion at least 48 hours prior to your submission or oral hearing.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Motion for severance

Motions for severance must state the basis for the severance.

The motion for severance must state the basis for the severance.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Order of severance

Must include

caption, case number

The order of severance must include styling, case number, parties, documents (with exact titles and dates), disposition, and cost responsibility.

The order of severance must include the following information: How you want the case to be styled. Case number, i.e. 2006-32041-A. What parties are to be severed into the severed case. What documents are to be severed into the severed case, (need exact title of document, image number and exact date filed) . State if the severed order disposes of the severed case or will it remain an active case. State who will pay for the cost of the severance.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Default judgment

Default judgments require an affidavit establishing that the defendant is not in active military service.

The federal Servicemembers’ Civil Relief Act (50 U.S.C. App. 521, § 201) requires that before granting a default judgment, state courts first obtain an affidavit that sets forth facts (i.e., not hearsay, and not matters asserted “on information and belief,” etc.) sufficient to show that the defendant against whom a default judgment is sought is not currently active and serving in the United States Armed Forces

Checked and corrected to match the court's document on Sep 20, 2026CRITICAL

Applies to

Motion

Must include

certificate of conference

A certificate of conference is required on all motions, pleas, and special exceptions, except for summary judgments, default judgments, non-suits, post-verdict motions, service-of-citation motions, and writs of sequestration.

A certificate of conference is required on all motions, pleas, and special exceptions EXCEPT for: * Motions for Summary Judgments * Defaults Judgments * Motions for voluntary dismissal or non-suit * Post-verdict motions * Motions involving service of citation * Writ of Sequestration

Checked against the court's document on Sep 20, 2026CRITICAL

Applies to

Motion to withdraw

Motions to withdraw must comply with Rule 10 TRCP; where the party will be pro se, the motion must include the party's phone number, address, email, a statement about consultation, and current deadlines and trial settings.

Motions to withdraw as attorney of record require strict compliance with Rule 10 of the Texas Rules of Civil Procedure. Motions in which the party will be pro-se litigant after the attorney withdraws must include: the party's telephone number; the party's address; the party's email address; a statement regarding consultation with the party regarding the motion; and current deadlines and trial settings.

Checked against the court's document on Sep 20, 2026CRITICAL

Applies to

Rule 106 motion

Rule 106 motions for substituted service must be accompanied by an affidavit verifying that the defendant lives/works at the address, listing each service attempt (minimum seven, including two before 7:30am and two after 7:30pm), identifying persons present, and noting cars or other indications of residence.

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 and time, there should be a minimum of seven attempts. Identify of persons who were present at the subject address and what was said. Identify of cars in the driveway or other indications that defendant resides at the subject address. At least two attempts before 7:30am AND two attempts after 7:30pm.

Checked against the court's document on Sep 20, 2026CRITICAL

Applies to

Notice of settlement

A notification of settlement must be filed to remove the case from the active trial docket.

Upon announcing settlement, a notification of settlement must be filed with the Court to remove the case from the active trial docket.

Checked against the court's document on Sep 20, 2026CRITICAL

Applies to

Motion to retain

Must include

proposed order

A proposed order must be filed for a verified motion to retain to be granted and to avoid dismissal for want of prosecution.

A proposed order must be filed in order for a verified motion to retain to be granted and avoidance of DWOP.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Motion

Agreed motions must include the signature of counsel for all parties.

Agreed motions must include the signature of counsel for all parties.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Motion

Must include

certificate of conference

Unopposed motions must include a certificate of conference.

Unopposed motions must include a certificate of conference.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Motion

Must include

certificate of conference

Parties must confer before filing discovery motions and include a certificate of conference.

Always confer before filing any motion related to discovery and include a certificate of conference.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Motion

Discovery motions must attach the discovery response at issue or state the request and answer verbatim in the body of the motion.

Be sure to attach a copy of the discovery response at issue or state verbatim the request and answer in the body of your motion.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Motion

All default judgment motions require an oral or submission hearing; foreclosure or damages proof-up requires an oral hearing.

All Motions for Default Judgment require either an oral or submission hearing. If you are requesting foreclosure or need to prove up damages, an oral hearing is required.

Checked and corrected to match the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Proposed order

The order of severance must contain the style of case, proposed new case number, parties, documents with filed dates, case status, and cost responsibility.

for the severance. The order of severance must contain the following: - Style of Case; - Proposed new case number / example 2006-00000-A; - Parties to be included in the severed case; - Each document to be included in the severed case along with the corresponding filed date and/or image number; - Whether the severed case has a final order, is to remain active, or is to be abated; and - The party paying for court cost

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Motion

A notice setting an oral hearing must be filed with a motion for summary judgment.

If you want an oral hearing on your MSJ, then you must file a notice setting same with your motion.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Motion

A written notice withdrawing the MSJ must be filed before it can be reset; otherwise the MSJ will be denied.

A written notice withdrawing the MSJ must be filed before the motion can be reset. If a written notice withdrawing the motion is not received prior to resetting the MSJ, the MSJ will be denied.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Motion

A motion to substitute counsel requires both attorneys' signatures or a hearing; with signatures and a proposed order, no hearing is needed.

Both the withdrawing and substituting attorneys' signatures must be present on the Motion to Substitute or, alternatively, it must be set for a hearing. Either submission or oral would suffice. If you have included the required signatures on the motion and filed a proposed order, it will be present to the Judge without the need for a hearing.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Motion

A motion to withdraw counsel requires the withdrawing attorney's and the party's signatures or a hearing; with signatures and a proposed order, no hearing is needed.

Both the withdrawing attorney's and the party's signature must be present on a Motion to Withdraw or, alternatively, it must be set for a hearing. Either submission or oral would suffice. If you have included the required signatures on the motion and filed a proposed order, it will be presented to the Judge without the need for a hearing.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Notice of motion

All hearing notices must include the hearing date and time, the motion filing date, and the motions to be heard.

All notices must include the date and time of the hearing, the date that the motion(s) was filed, and the motion(s) to be heard.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Motion

Must include

proposed order

Motions seeking a ruling and responses must be filed with a corresponding proposed order.

Motions seeking a ruling should be filed with a corresponding proposed order. Responses should also be filed with a corresponding proposed order.

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

Civil cases

Applies to

Motion or other document seeking relief

Must include

proposed order, certificate of service, 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.

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.

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

Civil cases

Applies to

Continuance or reset motion

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.).

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

Civil cases

Applies to

Discovery motion

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.

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

Civil cases

Applies to

Discovery motion and proposed order

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.

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

Civil cases

Applies to

Motion to amend citation

Must include

proposed order

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.

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

Civil cases

Applies to

Default judgment motion for attorney fees

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.

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

Civil cases

Applies to

Request for attorney fees as sanctions

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.

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

Civil cases

Applies to

Severance motion and order

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.

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

Civil cases

Applies to

Special exception

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).

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

Civil cases

Applies to

Rule 106 substituted service motion

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.

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

Civil cases

Applies to

Trial or pretrial deadline continuance motion

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.

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

Civil cases

Applies to

Motion

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.

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

Civil cases

Applies to

Late response

Must include

proposed order

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.

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

Civil cases

Applies to

Motion

Must include

certificate of conference

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.

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

Civil cases

Applies to

Motion

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.

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

Civil cases

Applies to

Proposed order

Do not combine multiple motions in one proposed order.

Do not combine multiple motions into a single proposed order.

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

Civil cases

Applies to

Oral hearing or hearing continuance request

Must include

proposed order

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.

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

Civil cases

Applies to

Summary judgment withdrawal notice

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.

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

Civil cases

Applies to

Proposed findings and conclusions

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.

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

Civil cases

Applies to

Minor settlement proposed final judgment

Must include

proposed order

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.

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

Civil cases

Applies to

Non suit dismissal or judgment

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.

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

Civil cases

Applies to

Final order

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.

Checked against the court's document on Sep 21, 2026CRITICAL

Applies to

Notice of hearing

All notices of oral hearing must contain the Zoom link and a link to the Tax Court Information Page.

ALL NOTICES OF ORAL HEARING MUST CONTAIN THE ABOVE ZOOM LINK AND A LINK TO THIS TAX COURT INFORMATION PAGE.

Checked against the court's document on Sep 20, 2026CRITICAL

Civil cases

Applies to

Proposed order

Must include

proposed order

A proposed order submitted after a hearing must include a cover letter indicating whether opposing counsel agrees to its form.

When submitting a proposed order after a hearing, include a cover letter and indicate whether the proposed order is agree to in form by opposing counsel.

Checked against the court's document on Sep 20, 2026CRITICAL

Civil cases

Applies to

Agreed motion

Must include

caption

Agreed/unopposed motions must be titled as such and contain the signatures of all parties in agreement.

All unopposed or agreed motions should be titled as such. All agreed motions and proposed orders must contain the signatures of all those in agreement.

Checked against the court's document on Sep 20, 2026CRITICAL

Civil cases

Applies to

Unopposed motion

Must include

certificate of conference

Unopposed motions must include a certificate of conference.

Unopposed motions must contain a certificate of conference.

Checked against the court's document on Sep 20, 2026CRITICAL

Civil cases

Applies to

Motion

Must include

certificate of conference

Every motion must be accompanied by a certificate of conference detailing efforts to discuss with opposing counsel; failure may result in the motion being passed.

All motions must be accompanied by a certificate of conference detailing the efforts undertaken to discuss the motion with opposing counsel. Failure to file a certificate of conference may result in a motion being passed.

Checked against the court's document on Sep 20, 2026CRITICAL

Civil cases

Applies to

Response

Must include

proposed order

Responses to motions must include a proposed order.

E-File responses to motions at least 24 hours prior to the hearing and include a proposed order.

Checked against the court's document on Sep 20, 2026CRITICAL

Civil cases

Applies to

Discovery motion

Discovery motions must outline the dispute, the efforts made to resolve it, and the relief requested.

If the parties must seek assistance with respect to discovery matters, the movant should file a motion outlining the discovery dispute, the effort made to resolve that dispute, and the relief requested from the Court.

Checked against the court's document on Sep 20, 2026CRITICAL

Civil cases

Applies to

Discovery motion

Motions seeking rulings on discovery objections must include an order with the specific requests, objections, and blanks to overrule or sustain.

If you are requesting the Court rule on objections, present a motion and order that contains the specific requests made along with the objections made and a blank to either overrule or sustain the objection.

Checked against the court's document on Sep 20, 2026CRITICAL

Civil cases

Applies to

Default judgment

Default judgment motions must be set for oral docket (not submission) and include exhibits showing service, non-military affidavit, certificate of last known address, and damages.

The parties shall file a motion for default judgment and set the same as a motion on the Court’s oral docket. Defaults are not to be submitted for submission, those that are will be passed. Please include all exhibits demonstrating service, non-military affidavit, certificate of last known address, and damages.

Checked against the court's document on Sep 20, 2026CRITICAL

Civil cases

Applies to

Motion

A motion for substituted service under Rule 106 must include an affidavit establishing the person can be found at the address and must use the Court's prescribed order.

If a party is seeking substituted service pursuant to 106 please provide a motion along with an affidavit that establishes that the person to be served can be found at the service address. Additionally, the parties should use the Court’s prescribed order.

Checked against the court's document on Sep 20, 2026CRITICAL

Civil cases

Applies to

Motion to withdraw

Motions to withdraw must include the party's telephone number, address, email address, current deadlines, and trial settings.

Motions to withdraw as attorney of record must contain the parties telephone number, address, email address, current deadlines and trial settings.

Checked against the court's document on Sep 20, 2026CRITICAL

Civil cases

Applies to

Order

Orders on motions to withdraw must include the pro se party's name, address, telephone number, and email; otherwise the motion will be denied.

Orders on motions to withdraw MUST include contact information for the pro se party including: name, address, telephone number and email address. Failure to include the required contact information will result in the motion being denied.

Checked against the court's document on Sep 20, 2026CRITICAL

Civil cases

Applies to

Special exception

Special exceptions must state the objected language verbatim and the reasoning in both the motion and the order.

Special exception should specifically state the language objected to and the reasoning for the objection. The language excepted to should be stated verbatim in the motion and the order.

Checked and corrected to match the court's document on Sep 20, 2026CRITICAL

Civil cases

Applies to

Severance motion

Motions for severance must include an order stating the style, new cause number, parties, documents, whether the case is disposed, and who pays costs.

SEVERANCE Motions for severance must include an order which states: The style of the case; The new cause number, e.g. 2018-12345A Parties to be included in the severed case Documents to be included in the severed case. Whether the severed order disposes of the severed case or if the case shall remain active. The party paying the costs of court and

Checked against the court's document on Sep 20, 2026CRITICAL

Civil cases

Applies to

Request for oral hearing

Do not file a blank request for an oral hearing date.

Do not file a blank request for an oral hearing date.

Checked against the court's document on Sep 20, 2026CRITICAL

Civil cases

Applies to

Motion

Motions requesting appointment of a guardian ad litem must include a brief description of the case and any other issues for the Court.

In motions requesting the appointment of a guardian ad litem, please include a brief description of the case and any other issues you would like the Court to consider.

Checked against the court's document on Sep 20, 2026CRITICAL

Civil cases

Applies to

Motion

Must include

proposed order

Every motion must be accompanied by a proposed order.

Please include an order with every motion filed.

Checked against the court's document on Sep 20, 2026CRITICAL

Civil cases

Applies to

Discovery motion

Discovery motions must attach the discovery response at issue or state verbatim the request and answer, and proposed orders must list each discovery issue separately.

You must attach a copy of the discovery response at issue or state verbatim the request and answer in the body of your motion. Proposed orders should list each discovery issue separately.

Checked against the court's document on Sep 20, 2026CRITICAL

Civil cases

Applies to

Special exception

Special exceptions motions must attach the pleading or state verbatim the paragraph excepted to, and proposed orders must list each exception separately, with an exception for damages-only exceptions.

Attach a copy of the pleading you are excepting to (unless the exception is only to the amount of damages sought) or state verbatim the paragraph to which you except. Proposed orders should list each exception separately.

Checked against the court's document on Sep 20, 2026CRITICAL

Civil cases

Applies to

Motion for substituted service

Motions for substituted service under Rule 106 must include an affidavit with specified information regarding service attempts and residence verification.

All motions for Substituted Service under Rule 106 must be accompanied by an affidavit that includes the following information or they are subject to being denied: Efforts taken verify that defendant actually lives or works at the subject address; Each attempt at service, with date and time; Identity of persons who were present at the subject address and what was said; and Identity of cars in the driveway or other indications that defendant actually resides at the subject address.

Checked against the court's document on Sep 20, 2026CRITICAL

Civil cases

Applies to

Motion to withdraw

Motions to withdraw as attorney of record will be considered only if the motion includes the required notices, statements, certificates, and client notification letters.

Because motions to withdraw as attorney of record usually impose the burden of a pro se case on opposing parties and the Court, they will be granted on a case by case basis. The following must be filed before any such motion will be considered: 1. Notice of hearing or submission. 2. A statement of the particular circumstances and disciplinary rules requiring withdrawal. A general statement such as “irreconcilable conflicts” is not enough. Matters which are confidential may be filed under seal. 3. A certificate by the attorney of record of the client’s name, address, and telephone number, whether such information is current, or if not current, when it was last known to be correct. 4. A copy of a letter from the attorney of record to the client giving notice: (a) that the attorney is withdrawing; (b) that the client is deemed to have knowledge of and is required to abide by the Texas Rules of Civil Procedure if the client proceeds pro se; (c) that all notices from the Court to the client’s current address will be deemed to have been received unless the client notifies the Court of any change of address; (d) that no continuances or extension will be granted to the pro se client in order to obtain other counsel; & (e) notice of submission or hearing at which the motion to withdraw will be considered. 5. In addition to the items described in #4 above, if the client is a corporation, the attorney must notify the client that a corporation cannot proceed pro se and if the corporation has not obtained new counsel within 30 days, a default judgment may be entered against the corporation if it is a defendant or its claims will be dismissed if it is a plaintiff. 6. A signed acceptance of the terms of the letter described in item 4, if the client has agreed to the withdrawal. If the client has not agreed to the withdrawal, proof of service of the letter described in items 4 & 5 must be filed.

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

Civil cases

Applies to

Proposed order

Do not combine multiple motions in one proposed order.

Do not combine multiple motions into a single proposed order.

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

Civil cases

Applies to

Filing citing an unpublished opinion

Counsel citing an unpublished opinion must provide its Westlaw citation.

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

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

Civil cases

Applies to

Motion or response

Must include

proposed order

Every motion and response, including objections to summary judgment evidence, must include a proposed order.

All motions and responses shall be accompanied by a proposed order. This requirement includes objections to summary judgment evidence.

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

Civil cases

Applies to

Pleading

Counsel must enter the pleading’s full title in the description field when submitting a document.

When submitting documents, counsel shall enter the full title of the pleading in the description field.

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

Civil cases

Applies to

Exhibit

Exhibits must be clearly labeled without all capital letters and filed separately.

Exhibits must be clearly labeled (without using all capital letters) and filed as separate documents.

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

Civil cases

Applies to

Motion

Agreed or unopposed motions must be clearly labeled accordingly.

Such motions must be clearly labeled “Agreed” or “Unopposed.”

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

Civil cases

Applies to

Motion, plea, or special exception

Must include

certificate of conference

Motions, pleas, and special exceptions require a certificate of conference, subject to the listed exceptions.

A certificate of conference is required on all motions (including discovery motions), pleas, and special exceptions except: ·         Motions for Summary Judgment; ·         Default Judgments; ·         Agreed Judgments; ·         Motions for Voluntary Dismissal or Non-Suit; ·         Post-Verdict Motions; and ·         Motions involving service of citation

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

Civil cases

Applies to

Motion

Must include

certificate of conference

A motion lacking a certificate confirming an actual discussion or explaining why none occurred will be passed.

Motions that do not include a certificate confirming that counsel has actually spoken with opposing counsel regarding the requested relief—or explaining why such a discussion has not occurred—will be passed.

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

Civil cases

Applies to

Certificate of conference

A certificate stating only that counsel sent a letter or email and received no response is insufficient.

A certificate of conference stating only that a letter or email was sent to opposing counsel and no response was received does not constitute a proper certificate of conference.

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

Civil cases

Applies to

Proposed order

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.

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

Civil cases

Applies to

Filing citing an unpublished opinion

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

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

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

Civil cases

Applies to

Filing citing legal authority

Counsel must ensure cited authorities exist and are quoted accurately.

Counsel are responsible for ensuring that all cited authorities exist and are accurately quoted.

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

Civil cases

Applies to

Discovery motion and proposed order

A discovery motion and its proposed order must identify each discovery issue separately.

The motion and proposed order must identify each discovery issue separately.

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

Civil cases

Applies to

Discovery proposed order

A discovery proposed order must list each disputed request or objection individually so the Court can rule item by item.

Proposed orders shall list each disputed request or objection individually, allowing the Court to grant or deny relief as to each item.

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

Civil cases

Applies to

Amended proposed judgment

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

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.

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

Civil cases

Applies to

Settlement involving minor children

All settlements involving minor children require a Guardian Ad Litem.

A Guardian Ad Litem is required in all settlements involving minor children.

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

Civil cases

Applies to

Guardian Ad Litem appointment request

Parties may not request a particular Guardian Ad Litem, and the Court will not appoint one selected or agreed upon by the parties or counsel.

The parties shall not request a particular Guardian Ad Litem for appointment, and the Court does not appoint Guardian Ad Litems selected or agreed upon by the parties or counsel.

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

Civil cases

Applies to

Minor settlement hearing request

Must include

proposed order

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.

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

Civil cases

Applies to

Default judgment motion seeking attorney’s fees

A motion for default judgment seeking attorney’s fees must include an affidavit with competent supporting evidence.

When seeking attorney’s fees in a motion for default judgment, the movant must include an affidavit providing competent evidence to support the claim.

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

Civil cases

Applies to

Motion to amend citation

If the defaulting party was served at an address different from the citation address, the movant must file a Motion to Amend Citation.

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.

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

Civil cases

Applies to

Motion to amend citation

Must include

proposed order

The Motion to Amend Citation should request correction to the address where valid service occurred and include a proposed order.

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.

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

Civil cases

Applies to

Motion for severance

A motion for severance must state its basis.

The motion must state the basis for the severance.

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

Civil cases

Applies to

Rule 106 motion for substituted service

A Rule 106 motion for substituted service must include an affidavit detailing address verification, service attempts, persons and vehicles observed, and facts supporting notice by the requested method.

Motions for substituted service under Texas Rule of Civil Procedure 106 must be supported by an affidavit that includes:  The efforts made to verify that the defendant resides or works at the address in question;  Each attempt at service, including the date and time;  The identity of any persons present at the address and what was said;  The identity of any vehicles observed or other indicia that the defendant resides at the address; and  Any additional facts demonstrating that the defendant will receive notice through the requested method of substituted service.

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

Civil cases

Applies to

Summary judgment motion or response

File or attach summary judgment evidence with the motion or response rather than incorporate previously filed materials by reference.

Summary judgment evidence should be filed or attached contemporaneously with the motion or response rather than incorporated by reference to materials previously filed.

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

Civil cases

Applies to

Oral hearing request

When obtaining an oral-hearing date, the party must provide an estimated hearing length and state whether a Court Reporter is required.

The party must provide an estimated time for the hearing and indicate whether a Court Reporter is required.

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

Civil cases

Applies to

Notice of Submission

A party setting a matter on the submission docket must file a Notice of Submission listing each motion’s exact title and serve all counsel and self-represented parties.

A party setting a matter on the submission docket shall file a Notice of Submission identifying the exact title of each motion and serve all counsel and self-represented parties.

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

Civil cases

Applies to

Written oral-hearing request

A party seeking an oral hearing on a submission-docket motion must file a written request.

Any party seeking an oral hearing on a motion set on the submission docket must file a written request.

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

Civil cases

Applies to

Summary judgment withdrawal notice

A party must file a written notice to withdraw a summary judgment motion.

To withdraw a motion for summary judgment, the party must file a written notice of withdrawal with the Court.

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

Civil cases

Applies to

Summary judgment withdrawal notice

The withdrawal notice must use the specified title and identify the original filing date.

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.

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

Civil cases

Applies to

Emergency motion

An emergency hearing request requires a written emergency motion detailing the basis for emergency relief.

To request an emergency hearing, a party must file a written emergency motion that provides a detailed explanation establishing the basis for emergency relief.

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

Civil cases

Applies to

Continuance motion and proposed order

Must include

proposed order

If parties also seek to amend the Docket Control Order, the motion must expressly request that relief and the proposed order must state that a new scheduling order will issue.

If the parties seek to amend the Docket Control Order in addition to continuing the trial setting, the motion must expressly request such relief and the proposed order state that a new scheduling order will be entered.

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

Civil cases

Applies to

Summer trial setting request or agreement

Parties requesting or agreeing to a summer trial setting must expressly waive conflicting vacation letters.

*If the parties request or agree to a summer trial setting, they must also expressly waive any vacation letters that would conflict with that setting.

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

Civil cases

Applies to

Motion or other document seeking relief

Must include

proposed order, certificate of service, certificate of conference

A filing seeking relief must include a certificate of service, any TRCP-required certificate of conference, 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.

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

Civil cases

Applies to

Hearing notice

After scheduling a hearing date with the clerk, file a notice of oral hearing or, when applicable, a notice of written submission.

Once you have scheduled any hearing date with the court clerk, follow up with a notice of oral hearing or (if applicable) notice of written submission.

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

Civil cases

Applies to

Agreed motion and order

An agreed motion and order should include signature blocks for all parties agreeing to the requested 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.”

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

Civil cases

Applies to

Motion

Must include

certificate of conference

Motions must include certificates of conference when required by the Texas Rules of Civil Procedure and local rules.

Motions must have certificates of conference as required by the Texas Rules of Civil Procedure and our local rules.

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

Civil cases

Applies to

Certificate of conference

Must include

certificate of conference

A certificate of conference must expressly describe efforts to resolve the motion with all other parties or counsel before filing.

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.

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

Civil cases

Applies to

Certificate of conference

Must include

certificate of conference

If the other side cannot be reached before filing, the certificate should describe communication efforts and be supplemented as soon as possible after conferral occurs.

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.

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

Civil cases

Applies to

Discovery motion or hearing request

Must include

certificate of conference

Discovery motions and discovery-hearing requests must include a certificate stating that a reasonable attempt to resolve the dispute without Court intervention failed.

All discovery motions or requests for hearings relating to discovery must contain a certificate by the party filing the motion or request that a reasonable effort has been made to resolve the dispute without the necessity of Court intervention and the effort failed.

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

Civil cases

Applies to

Motions pleas and special exceptions

Must include

certificate of conference

The conference-certificate requirement extends to motions, pleas, and special exceptions, except for the listed categories.

The certificates of conference required by the TRCP are extended to all motions, pleas and special exceptions except summary judgments, default judgments, agreed judgments, motions for voluntary dismissal or non-suit, post-verdict motions and motions involving service of citation.

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

Civil cases

Applies to

Severance motion and order

A severance motion and order must state the severed case’s status and whether it will be interlocutory or final and appealable upon severance.

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.

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

Civil cases

Applies to

Rule 106 substituted service motion

A Rule 106 substituted-service motion must include an accompanying affidavit containing the specified information.

All motions for substituted service under Rule 106 must be accompanied by an affidavit that includes the following information:

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

Civil cases

Applies to

Rule 106 motion

Must include

proposed order

A Rule 106 motion should include the Court’s form order.

Any Rule 106 Motion should be accompanied by the court’s form order.

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

Civil cases

Applies to

Trial or pretrial deadline continuance motion

Trial or pretrial-deadline continuance motions must include an appropriate affidavit unless agreed.

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

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

Civil cases

Applies to

Non suit dismissal or judgment

Non-suits, dismissals, and judgments should be titled as interlocutory or final.

All non-suits, dismissals and judgments should be titled as interlocutory or final.

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

Civil cases

Applies to

Interlocutory order

An interlocutory order should expressly identify the parties and claims dismissed and those remaining.

Interlocutory orders should expressly list which parties and claims are being dismissed and which remain (if any).

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

Civil cases

Applies to

Final order

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.

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

Civil cases

Applies to

Non suit motion notice or order

Non-suit motions, notices, and orders should expressly state that 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 to Rule 162 of the Texas Rules of Civil Procedure.

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

Civil cases

Applies to

Trial materials

The parties must exchange the listed trial materials before Docket Call.

The 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.

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

Civil cases

Applies to

Exhibit

An exhibit related to any witness’s criminal conviction must be shared with opposing counsel no later than Docket Call.

Any exhibit related to a criminal conviction of any witness MUST be shared with opposing counsel NO LATER than Docket Call.

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

Civil cases

Applies to

Deposition excerpts

Deposition excerpts for any witness expected to testify by deposition must be provided to opposing counsel before Docket Call.

Provide to opposing counsel deposition excerpts for any witness anticipated to testify by deposition PRIOR to the docket call.

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

Civil cases

Applies to

Proposed findings conclusions

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.

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

Civil cases

Applies to

Adr

The standard docket control order requires the parties to complete alternative dispute resolution.

The court’s standard docket control order requires the parties to complete ADR.

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

Civil cases

Applies to

Case conduct

Violations of these procedures or other court orders or instructions are punishable by contempt.

Violations of these procedures (or of other orders and/or instructions of the court) are punishable by contempt.

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

Civil cases

Applies to

Application

Applicants seeking inclusion on the Court’s list must submit a written request and complete resume, should list special capabilities, and must confirm current professional liability coverage.

Those wishing to be included in the Court’s list must submit a written request with a complete resume that details the nature of the applicant’s experience as a civil trial practitioner.  Special capabilities, such as fluency in languages other than English, background in finance,  and the like, also  should  be listed.  Applicants also must confirm that professional liability coverage is in effect and will remain current.

Checked against the court's document on Sep 20, 2026CRITICAL

Civil cases

Applies to

Motion

Must include

proposed order

A proposed order must be filed with every motion and response before the hearing, or the hearing will be passed.

ALL Motions and Responses filed with the Court must have a Proposed Order filed with the Court before the hearing or the hearing will automatically be passed.

Checked against the court's document on Sep 20, 2026CRITICAL

Civil cases

Applies to

Motion

Must include

certificate of conference

Motions require a certificate of conference unless they are for default judgment, summary judgment, or dismissal.

All Motions require a Certificate of Conference, with the following exceptions: Motion for Default Judgment, Motion for Summary Judgment and Motion to Dismiss.

Checked against the court's document on Sep 20, 2026CRITICAL

Civil cases

Applies to

Certificate of conference

The certificate of conference must detail efforts to resolve issues and sufficient communication attempts; a bare statement of sending a letter is insufficient.

The Certificate of Conference should include a detailed statement of the movant’s efforts to resolve the issues in the motion with opposing counsel/party prior to filing the motion. 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. A statement along the lines of, "Counsel faxed, emailed, or mailed a letter to opposing counsel and they did not respond," is NOT sufficient to meet the requirement to confer.

Checked against the court's document on Sep 20, 2026CRITICAL

Civil cases

Applies to

Motion for substituted service

Motions for substituted service require an affidavit verifying at least 5 attempts of personal service.

Motions for Substituted Service will not be granted without an affidavit verifying that at least 5 attempts of personal service have been made.

Checked against the court's document on Sep 20, 2026CRITICAL

Civil cases

Applies to

Motion for preferential setting

Must include

proposed order

Preferential setting requires a motion and proposed order, stating the reason, and a signed order.

Counsel must file a Motion and Proposed Order. The motion must notate the reason for need of the preferential setting. There must be a signed order in the case file for a case to be observed as a preferential setting case.

Checked and corrected to match the court's document on Sep 20, 2026CRITICAL

Civil cases

Applies to

Trial notebook

Trial notebooks must contain motion in limine and order, exhibit list, witness list, and proposed order on all objections.

All parties must prepare, exchange, and bring to the pretrial conference, a Trial Notebook that contains: * Motion in Limine and Order * Exhibit List * Witness List * Proposed Order on ALL Objections

Checked against the court's document on Sep 20, 2026CRITICAL

Civil cases

Applies to

Continuance motion

Must include

proposed order

A proposed order must accompany all motions for continuance.

A Proposed Order must be filed with all Motions for Continuances.

Checked against the court's document on Sep 20, 2026CRITICAL

Civil cases

Applies to

Trial binder

Counsel must provide a hardcopy trial binder to the Court.

Counsel must provide the Court with a hardcopy trial binder.

Checked against the court's document on Sep 20, 2026CRITICAL

Civil cases

Applies to

Proposed jury charge

Parties must submit proposed jury charge/findings and final judgment via email in Word or on a thumb drive.

All parties are to submit a Proposed Jury Charge/Findings of Fact and Conclusions of Law and Proposed Final Judgment to the Court via email in Word Format or on a thumb drive.

Checked against the court's document on Sep 20, 2026CRITICAL

Civil cases

Applies to

Proposed order severance

Proposed order of severance must include the listed elements.

The proposed Order of Severance should include the following: How the severed case is to be styled. The new cause number- (A) (B) (C) The parties to be included in the severed case. All the pleadings that are to be severed into the new file, which include document title, document filed date, and image number. Whether the Order disposes of the severed case, or whether it will remain an active case; and Who will pay for the costs of severance.

Checked against the court's document on Sep 20, 2026CRITICAL

Civil cases

Applies to

Notice of settlement

A notification of settlement must be filed when settlement is announced to remove the case from the active trial docket.

Upon announcing settlement, a notification of settlement must be filed with the Court to remove the case from the active trial docket.

Checked against the court's document on Sep 20, 2026CRITICAL

Civil cases

Applies to

Motion to reinstate

If a case is DWOP'd for failure to file judgment/non-suit, counsel must file a motion to reinstate and formally set it for ruling.

If the case is DWOP'd due to failure to file judgment/non-suit, counsel will have to file a motion to reinstate the case and set the reinstatement formally before the Court for ruling.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Certificate

Must include

certificate of conference

Certificates of conference must include the method and timing of conferral, the names of participants, and whether relief is opposed or agreed.

Certificates of conference must state: how and when parties conferred on the matters on which relief is sought; the names of the attorneys/parties who conferred; and whether the relief is opposed, agreed, or agreed in part.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Motion

Must include

proposed order

Every motion and response must have a proposed order filed before the hearing.

All motions and responses must have a proposed order filed in advance of the hearing on that motion.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Discovery motion

Must include

certificate of conference

Discovery motions must include a brief description of the dispute, a certificate of conference with details of discussions, and copies of the discovery requests and responses at issue.

The complaining party should file a motion containing: a brief description of the dispute; a certificate of conference stating the name of all counsel participating in the discussions, including the date, time, and place the parties have had out of-court discovery discussions, and the results of those discussions; and a copy or verbatim reproduction of the discovery requests and responses at issue.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Settlement

A Guardian Ad Litem is required for settlements involving minor children unless the Court approves proceeding without one at an in-person status conference.

A Guardian Ad Litem will be required for all settlements involving minor children, unless the Court has been advised of same and approved proceeding without a guardian ad litem during an in person status conference.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Motion

Must include

proposed order

Parties must submit an agreed motion and order for appointment of a Guardian Ad Litem; the Court selects the GAL and informs the parties.

The parties are to submit an agreed motion and order for appointment of a Guardian Ad Litem. The Court will then select the Guardian Ad Litem for that case, and will inform the parties of the Court's decision.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Proposed order

The proposed Order of Severance must include styling, new cause number, parties, pleadings to sever, disposition status, and cost responsibility.

The proposed Order of Severance should include the following: how the severed case is to be styled; the new cause number; the parties to be included in the severed case; all the pleadings that are to be severed into the new file; whether the Order disposes of the severed case, or whether it will remain an active case; and who will pay for the costs of severance.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Motion

Must include

certificate of service

Withdrawal motions must include a statement of circumstances, a certificate with client contact info, a copy of the notice letter with specified contents, and proof of service if the client has not agreed.

The motion must contain: a statement of the particular circumstances and disciplinary rules requiring withdraw; a certificate of the attorney of record of the client’s name, address, telephone number, e-mail address and the last known time the information was correct; a copy of a letter from the attorney of record to the client giving notice: (a) that the attorney is withdrawing; (b) that the client is deemed to have knowledge of and is required to abide by the Texas Rules of Civil Procedure if the client proceeds pro se; (c) that all notices from the Court to the client's current address will be deemed to have been received unless the client notifies the Court of any change of address; (d) that no continuances or extensions will be granted to the pro se client in order to obtain other counsel; and (e) notice of the hearing at which the motion to withdraw will be considered; and If the client has not agreed to the withdraw, proof of service of the letter described above must be filed.

Checked against the court's document on Sep 21, 2026CRITICAL

Civil cases

Applies to

Exhibits

Demonstrative exhibits and PowerPoint presentations must be shown to all parties before being shown to the jury.

All demonstrative exhibits and Power Point presentations must be shown to all parties before being shown to the jury.

Checked against the court's document on Sep 21, 2026WARNING

Civil cases

Applies to

E filed document

E-filed documents must have full title in description field, separately filed exhibits with numbers, and no all caps.

When filing documents, please type the entire title of your pleading in the description field and clearly label all exhibits. Do not use all caps. Each exhibit should be filed separately. Exhibits should be numbered, not by letter.

Checked against the court's document on Sep 21, 2026WARNING

Civil cases

Applies to

Discovery motion

Must include

proposed order

Discovery motion proposed orders must list each issue separately, and both movant and non-movant must submit proposed orders.

Proposed orders should list each discovery issue separately. Both the movant and non-movant must submit a proposed order.

Checked against the court's document on Sep 21, 2026WARNING

Civil cases

Applies to

Minor settlement

Must include

proposed order

For settlements involving minors with conflict of interest, parties must submit agreed motion/order for Guardian Ad Litem, and at hearing present proposed judgment and ad litem fee report.

A Guardian Ad Litem will be required for all settlements involving minor children. This applies when there is a conflict of interest between the minor(s) and the parent or legal guardian. The parties are to submit an agreed motion and order for appointment of a Guardian Ad Litem. The Court will then select the Guardian Ad Litem for that case, and will inform the parties of the Court's decision. Once a Guardian Ad Litem has been appointed, the parties may contact the Court Clerk in order to obtain a Minor Settlement hearing date. At the time of the hearing, the parties are to present the proposed Judgment, as well as the Supreme Court ad litem fee report.

Checked against the court's document on Sep 21, 2026WARNING

Civil cases

Applies to

Default judgment

HOA default judgment motions must be set for oral hearing and include review of lien language, deed, and accounting.

Motions for Default Judgment based upon unpaid assessments or deed restriction violations must be set for an oral hearing; however, a board member or property manager does not need to be present at the hearing. The Court would like to review the following three documents at the hearing: the lien foreclosure language in the declarations; the deed; and the accounting.

Checked against the court's document on Sep 21, 2026WARNING

Civil cases

Applies to

Motion for severance

Must include

proposed order

Severance motion must state basis and proposed order must include listed items.

Motions for Severance may be set either for submission or oral hearing. The motion must state the basis for the severance. The proposed Order of Severance should include the following: how the severed case is to be styled; the cause number; the parties to be included in the severed case; all the pleadings that are to be severed into the new file; whether the Order disposes of the severed case, or whether it will remain an active case; and who will pay for the costs of severance.

Checked against the court's document on Sep 21, 2026WARNING

Civil cases

Applies to

Notice of submission

When setting a matter on submission docket, file notice of submission with exact motion titles and serve on all parties.

If you set a matter on the submission docket file a notice of submission with the exact title of the motion or motions set for consideration and serve it on all counsel and self-represented parties.

Checked against the court's document on Sep 21, 2026WARNING

Civil cases

Applies to

Temporary injunction

Must include

proposed order

Moving party must submit proposed temporary injunction order before hearing starts.

The moving party must submit a proposed temporary injunction order before the hearing begins.

Checked against the court's document on Sep 21, 2026WARNING

Civil cases

Applies to

Pleading

Must include

exhibit list

When e-filing, type the full pleading title in the description field, label exhibits clearly, avoid all caps, and file each exhibit separately.

When filing documents, please type the entire title of your pleading in the description field and clearly label all exhibits. Do not use all caps. Each exhibit should be filed separately.

Checked against the court's document on Sep 21, 2026WARNING

Civil cases

Applies to

Discovery motion

Must include

proposed order

Discovery proposed orders must list each issue separately, and both movant and non-movant must submit a proposed order.

Proposed orders should list each discovery issue separately. Both the movant and non-movant must submit a proposed order.

Checked against the court's document on Sep 21, 2026WARNING

Civil cases

Applies to

Severance motion

A motion for severance must state the basis for the severance.

The motion must state the basis for the severance.

Checked against the court's document on Sep 21, 2026WARNING

Civil cases

Applies to

Order of severance

The proposed Order of Severance must include specified details about styling, cause number, parties, pleadings, disposition, and costs.

The proposed Order of Severance should include the following: how the severed case is to be styled; the cause number; the parties to be included in the severed case; all the pleadings that are to be severed into the new file; whether the Order disposes of the severed case, or whether it will remain an active case; and who will pay for the costs of severance.

Checked against the court's document on Sep 21, 2026WARNING

Civil cases

Applies to

Notice of oral hearing

The notice of oral hearing must state the exact title of the motion or motions to be heard.

The hearing notice must state the exact title of the motion or motions to be heard.

Checked against the court's document on Sep 20, 2026WARNING

Applies to

Proposed order

The proposed order on a discovery motion should list each discovery issue separately so the court may rule on each.

The proposed order should list each discovery issue separately so that the court may deny or grant each issue.

Checked against the court's document on Sep 20, 2026WARNING

Applies to

Proposed order

The order granting substituted service should conform to the prescribed form.

The Order granting the substituted service should comport with this form to be found here.

Checked against the court's document on Sep 20, 2026WARNING

Applies to

Motion to substitute counsel

Must include

certificate of conference

Motions to substitute counsel require signed signature blocks of outgoing and incoming attorneys, or a certificate of conference showing agreement; if not agreed, a hearing is required.

Parties need to have a signed signature block of the outgoing & incoming attorney or attach a Certificate of Conference stating all parties are in agreement of substitution. If not agreed by all, this will need to be set for a hearing.

Checked against the court's document on Sep 20, 2026WARNING

Applies to

Motion to withdraw

When the withdrawing attorney represents a corporation, counsel must notify the corporate party that corporations cannot proceed pro se in Texas courts.

If the withdrawing attorney represents a corporation, counsel must notify the corporate party that corporations cannot proceed pro-se or self-represented in Texas courts.

Checked against the court's document on Sep 20, 2026WARNING

Applies to

Trial binder

The trial binder should contain the motion in limine, exhibits, exhibit lists, witness lists, and page line designations.

The trial binder should contain the motion in limine, exhibits, exhibit lists, witness lists, and page line designation.

Checked against the court's document on Sep 20, 2026WARNING

Applies to

Motion in limine

Motions in Limine should not duplicate the Court's standing Order in Limine and should be limited to case-specific items.

The Court has adopted a standing Order in Limine applicable to all cases. Do not duplicate these items in your Motions in Limine. Your motion should be limited to only those items specific to the facts and circumstances in your case.

Checked against the court's document on Sep 20, 2026WARNING

Applies to

Jury questionnaire

Do not bring a jury questionnaire to the first day of trial.

Do not bring a jury questionnaire to the first day of trial.

Checked and corrected to match the court's document on Sep 20, 2026WARNING

Applies to

Minor settlement

Must include

proposed order

A Guardian ad Litem is required for all settlements involving minor children; parties must submit a motion and order to request one, and the minor must be present at the settlement hearing.

A Guardian Ad Litem will be required for all settlements involving minor children. The parties must submit a motion and order to request a Guardian Ad Litem. * Minor must be present for the minor settlement hearing.

Checked against the court's document on Sep 20, 2026WARNING

Civil cases

Applies to

Objections

The deposition itself must be submitted when filing objections.

When filing objections the deposition itself must be submitted.

Checked against the court's document on Sep 21, 2026WARNING

Civil cases

Applies to

Proposed order

Proposed orders for discovery motions should list each discovery issue separately.

Proposed orders should list each discovery issue separately.

Checked against the court's document on Sep 21, 2026WARNING

Civil cases

Applies to

Motion

Ex parte motions must be labeled as ex parte in the title of the motion.

Ex Parte Motions (Please label as ex parte in the title of the motion.)

Checked against the court's document on Sep 21, 2026WARNING

Civil cases

Applies to

Motion

Agreed and unopposed motions must be labeled as such in the title of the motion.

Agreed/Unopposed Motions (Please label as such in the title of the motion.

Checked against the court's document on Sep 21, 2026WARNING

Civil cases

Applies to

Motion

If the motion title includes 'emergency', no separate emergency hearing request is needed.

If the motion itself includes "emergency" in the title, there is no need to file a separate request.

Checked against the court's document on Sep 21, 2026WARNING

Civil cases

Applies to

Proposed order

Proposed orders on motions to compel and special exceptions should delineate each item.

Proposed orders on motions to compel and special exceptions should delineate each item.

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

Civil cases

Applies to

Filing with exhibits

Exhibits should be indexed.

Please index your exhibits.

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

Civil cases

Applies to

First or second agreed continuance

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.

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

Civil cases

Applies to

Motion

Must include

proposed order

Motions should be accompanied by an order.

All motions should be accompanied with an Order.

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

Civil cases

Applies to

Motion

Unopposed and agreed motions should be titled accordingly.

All unopposed or agreed motions should be titled as such.

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

Civil cases

Applies to

Agreed motion and order

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.

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

Civil cases

Applies to

Rule 106 motion

Must include

proposed order

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.

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

Civil cases

Applies to

Filing citing unpublished opinion

Counsel citing an unpublished opinion must provide its Westlaw citation.

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

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

Civil cases

Applies to

Filing citing unpublished opinion

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.

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

Civil cases

Applies to

Certificate of conference

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.

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

Civil cases

Applies to

Discovery proposed order

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.

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

Civil cases

Applies to

Proposed order submission

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.

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

Civil cases

Applies to

Temporary injunction hearing submission

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.

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

Civil cases

Applies to

Non suit motion notice or order

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.

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

Civil cases

Applies to

Dismissal

Dismissals should be filed with prejudice.

All dismissals should be filed with prejudice.

Checked against the court's document on Sep 20, 2026WARNING

Civil cases

Applies to

Severance order

Severance orders must delineate the parties, claims, and pleadings incorporated into the severed case.

The order granting severance should properly delineate the parties and claims remaining and being severed, respectively, as well as the pleadings being incorporated into the severed case, as appropriate.

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

Civil cases

Applies to

Attorney-fee affidavit in default judgment motion

The attorney-fee affidavit should address counsel’s experience, work performed, time spent, and hourly rate.

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.

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

Civil cases

Applies to

Proposed order of severance

A proposed severance order should identify the new case style and number, included parties and pleadings, case status, and party responsible for costs and fees.

The proposed Order of Severance should include the following:  The style of the severed case;  The cause number;  The parties to be included in the severed case;  The pleadings to be severed into the new file;  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.

Checked against the court's document on Sep 21, 2026WARNING

Civil cases

Applies to

Motion

If only one side believes the matter is an emergency, that party must file a motion for an emergency hearing.

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

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

Civil cases

Applies to

Filing with exhibits

Filings with exhibits should include an exhibit index.

Please index your exhibits.

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

Civil cases

Applies to

Unopposed or agreed motion

Unopposed and agreed motions should be titled to identify them as unopposed or agreed.

All unopposed or agreed motions should be titled as such.

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

Civil cases

Applies to

Certificate of conference

Must include

certificate of conference

If opposing counsel does not return repeated calls or messages, describe the efforts to confer in the certificate.

If opposing counsel refuses to return numerous phone calls or other messages, describe your efforts to confer in your certificate of conference.

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

Civil cases

Applies to

Motion or request to dismiss or nonsuit minor claim

When dismissing or nonsuiting a minor’s claim, provide information on whether the minor is receiving a settlement so the Court can assess appointment of a guardian ad litem.

If you are seeking to dismiss or nonsuit a minor's claim, the Court will want to know whether the minor is receiving a settlement to determine whether a guardian ad litem should be appointed.

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

Civil cases

Applies to

Ad litem or other appointee fee form

Ad litems and other appointees must use the Texas Supreme Court form to report their fees and who pays them.

The Texas Supreme Court has created a new form for ad litems (of all types) and other appointees to fill out regarding the amounts of their fees and by whom they are paid.

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

Civil cases

Applies to

Exhibit list

Provide accurate exhibit lists to Judge Aston and the court reporter.

Accurate exhibit lists should be furnished to Judge Aston and to the court reporter.

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

Civil cases

Applies to

Exhibit

Redact exhibits before offering them.

Redactions should be made prior to the exhibit being offered.

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

Civil cases

Applies to

Exhibit

An exhibit redacted after admission must be marked as an “A” exhibit, and the court reporter keeps the original unredacted exhibit for the record.

Exhibits redacted after the exhibit is admitted (subject to redaction or without initial objection) are to be marked as an “A” exhibit and the original, unredacted exhibit is kept by the court reporter for the record.

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

Civil cases

Applies to

Exhibit

An assigned exhibit number cannot be reused, even if the original exhibit is withdrawn or unused.

Once an exhibit number has been assigned, the same exhibit number may not be used for another exhibit, even if the original exhibit is withdrawn or not used in the hearing or trial.

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

Civil cases

Applies to

Deposition testimony offer

Provide the court reporter with deposition page-and-line designations and a non-condensed transcript before offering the testimony.

Page/line designations of deposition testimony, along with a non-condensed copy of the transcript, are to be furnished to the court reporter prior to the offer.

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

Civil cases

Applies to

Written deposition testimony

When reading written deposition testimony aloud, say “Question” before each question and “Answer” before each answer.

When one person is reading from written deposition testimony, the reader must say “Question” prior to reading each question and “Answer” prior to reading each answer.

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

Civil cases

Applies to

Courtroom attire

Exposed undergarments are not permitted in court.

No exposed undergarments

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

Civil cases

Applies to

Video deposition excerpts

Video deposition excerpts should be prepared before trial and kept as short as possible.

Prepare video deposition excerpts prior to trial, keeping the length as short as possible.

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

Civil cases

Applies to

Motion

If objections to deposition excerpts remain, the party seeking exclusion should file a motion as soon as possible 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, 2026WARNING

Civil cases

Applies to

Motion

If the parties cannot agree on deposition form objections, the party seeking to overrule an objection 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 objections.

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

Civil cases

Applies to

Courtroom attire

Excessively low-rise pants, skirts, and shorts are not permitted in court.

No excessively low-rise pants, skirts, or shorts

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

Civil cases

Applies to

Jury charges

Draft proposed jury charges should be exchanged before the Docket Call date.

Drafts of proposed jury charges should be exchanged PRIOR to the docket call date.

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

Civil cases

Applies to

Jury questionnaire

Any jury questionnaire questions the parties cannot agree on should be presented to Judge Aston by submission or oral hearing before Docket Call.

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

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

Civil cases

Applies to

Mediation objection

A party who believes its case is definitely unsuitable for mediation should file an objection as soon as practicable and place it on the submission docket.

If you believe that your case is definitely not appropriate for mediation, file an objection to mediation as soon as practicable and put it on the submission docket.

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

Civil cases

Applies to

Courtroom attire

Counsel are expected to wear professional attire and should advise parties, witnesses, and support staff to dress appropriately.

Cousnel are expected to wear professional attire. Please advise all parties, witnesses, and support staff to dress appropriately as well.

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

Civil cases

Applies to

Courtroom attire

Midriff-baring and suggestive clothing are not permitted in court.

No midriffs or suggestive clothing

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

Civil cases

Applies to

Courtroom attire

Ripped clothing is not permitted in court.

No ripped clothing

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

Civil cases

Applies to

Courtroom attire

Tank tops and halter-style garments are not permitted in court.

No tank tops or halter-style garments

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

Civil cases

Applies to

Courtroom attire

Clothing with offensive language or images, or advertising alcohol or drugs, is not permitted in court.

No clothing with offensive language or images, or advertising alcohol or drugs

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

Civil cases

Applies to

Courtroom conduct

Witnesses and support staff should be informed of courtroom decorum and limit activity while witnesses are questioned and attorneys address the jury.

Please make witnesses and support staff aware of courtroom decorum and limit activity while witnesses are being questioned and while attorneys are addressing the jury.

Checked against the court's document on Sep 20, 2026WARNING

Civil cases

Applies to

Discovery motion

Discovery motions must specify each discovery response at issue and include a copy or state the request and answer verbatim.

Discovery Motions should specify each specific discovery response at issue and include a copy of the response(s) at issue as sub-documents when e-filing, or state verbatim the request and answer in the body of your motion.

Checked against the court's document on Sep 20, 2026WARNING

Civil cases

Applies to

Proposed order

Proposed orders for discovery motions must list each discovery issue separately.

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

Checked against the court's document on Sep 20, 2026WARNING

Civil cases

Applies to

Motion in limine

Motions in limine should not duplicate the standing order but only address case-specific items.

The Court has adopted a standing Order in Limine applicable to all cases. Do not duplicate these items in your Motions in Limine. Your motion should be limited to only those items specific to the facts and circumstances in your case.

Checked against the court's document on Sep 20, 2026WARNING

Civil cases

Applies to

Special exception motion

Special exceptions require attaching the pleading or stating verbatim paragraphs, and proposed orders list each exception separately.

Attach a copy of the pleading you are excepting to as an exhibit (unless the exception is only to the amount of damages sought) or state verbatim which paragraphs you except to. Proposed orders should list each exception separately.

Checked against the court's document on Sep 21, 2026WARNING

Civil cases

Applies to

Proposed order

The proposed order must include the exact title of the motion it addresses.

The proposed order should include the exact title of the motion being considered.

Checked against the court's document on Sep 21, 2026WARNING

Civil cases

Applies to

Legal authority

When presenting statutory or case law at a hearing, provide a copy with relevant portions highlighted.

If statutory or case law will be presented to the Court at any hearing, a copy of the statute or case should be made available with highlighted portions of the relevant language.

Checked against the court's document on Sep 21, 2026WARNING

Civil cases

Applies to

Discovery motion

Must include

proposed order

After filing a discovery motion, contact the Court for a hearing; proposed orders must list each issue separately, and both movant and non-movant must submit proposed orders.

After filing the motion, the complaining party should contact the Court about a hearing. Proposed orders should list each discovery issue separately. Both the movant and non-movant must submit a proposed order.

Checked against the court's document on Sep 21, 2026WARNING

Civil cases

Applies to

Motion

Severance motions may be set for submission or oral hearing and must state the basis for severance.

Motions for Severance may be set either for submission or oral hearing. The motion must state the basis for the severance.

Checked against the court's document on Sep 21, 2026WARNING

Civil cases

Applies to

Motion

Rule 106 substituted service requests must use the court's suggested form.

Parties requesting an Order for Substituted Service under Rule 106 shall use the court’s suggested form: 157th Order Granting 106 Substitute Service.docx

Checked against the court's document on Sep 21, 2026INFO

Civil cases

Applies to

Default judgment hearing

At the HOA default hearing, the Court will review the lien foreclosure language, the deed, and the accounting.

The Court would like to review the following three documents at the hearing: the lien foreclosure language in the declarations; the deed; and the accounting.

Checked against the court's document on Sep 21, 2026INFO

Civil cases

Applies to

Order substituted service

Parties should use the court's suggested form for Rule 106 substituted service orders.

Parties requesting an Order for Substituted Service under Rule 106 should use the court’s suggested form: 164th Order Granting Rule 106 Substitute Service.pdf.

Checked against the court's document on Sep 21, 2026INFO

Civil cases

Applies to

Order substituted service publication

Parties should use the court's suggested form for Rule 109 substituted service by publication orders.

Parties requesting an Order for Substituted Service by Publication under Rule 109 should use the court’s suggested form: ORDER GRANTING SERVICE BY PUBLICATION(revised Aug. 2022).pdf

Checked against the court's document on Sep 21, 2026INFO

Civil cases

Applies to

Request for oral hearing

A party wanting an oral hearing on a submission docket motion should file a written request with the Court.

If any party wants an oral hearing on a motion that has been placed on the submission docket that party should file a written request with the Court.

Checked against the court's document on Sep 21, 2026INFO

Civil cases

Applies to

Motion in limine

Motions in limine should not duplicate the standing order and should be limited to case-specific issues.

Do not duplicate these items in your motions in limine. Rather, your motion should be limited to other items, and specifically to limine issues that are peculiar to the facts of your case.

Checked against the court's document on Sep 21, 2026INFO

Civil cases

Applies to

Motion

If an agreed motion is denied without a hearing, a subsequent oral hearing may be requested.

If an agreed motion is denied without a hearing, you can request a subsequent oral hearing on the motion.

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

Civil cases

Applies to

Special exception proposed order

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.

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

Civil cases

Applies to

Supreme court ad litem fee report

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.

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

Civil cases

Applies to

Proposed Final Judgment

The proposed Final Judgment may be amended before the hearing if necessary.

The proposed Final Judgment may be amended before the hearing, if necessary.

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

Civil cases

Applies to

Supreme Court Ad Litem Fee Report

The Court prefers advance filing of the Supreme Court Ad Litem Fee Report, 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.

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

Civil cases

Applies to

Proposed amended scheduling order

As an alternative, parties may submit a proposed amended scheduling order for the Court’s consideration.

Alternatively, the parties may submit a proposed amended scheduling order for the Court’s consideration.

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

Civil cases

Applies to

Exhibits

The parties should be prepared to identify to Judge Aston the exhibit numbers to which they have no objection.

Be prepared to advise Judge Aston of exhibit numbers for which you have no objection.

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

Civil cases

Applies to

Motion in limine

The Court asks parties to tailor motions in limine to the issues in the case rather than filing boilerplate motions.

Please work diligently to hone your Motion in Limine to the issues in the case rather than a boilerplate “everything but the kitchen sink” motion.

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

Civil cases

Applies to

Proposed findings conclusions

Proposed findings and conclusions may be revised and filed after trial as allowed by the Texas Rules of Civil Procedure.

These proposed findings and conclusions may, of course, be revised and filed subsequent to the trial as allowed by the TRCP.

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

Civil cases

Applies to

Mediation objection motion

An agreed motion objecting to mediation will almost always be granted.

An agreed motion objecting to mediation will almost always be granted.

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

Civil cases

Applies to

Courtroom attire

Courtroom attendees are asked to bathe and avoid excessive perfume.

Bathe, do not over-perfume

The quote is in the court's document. The summary is not checked yet.CRITICAL?

Applies to

Exhibits

Any exhibits that need to be redacted MUST be done prior to the time you arrive for the beginning of trial.

Summary: Redaction of exhibits must be completed before arriving for trial.

The quote is in the court's document. The summary is not checked yet.CRITICAL?

Applies to

Motion

Must include

proposed order

All motions and responses must include a proposed order.

The quote is in the court's document. The summary is not checked yet.CRITICAL?

Applies to

Motion

Must include

certificate of conference

You must confer with your opposing counsel prior to filing all motions and include a detailed certificate of conference, with the following exceptions: motions for default judgments, motions for summary judgment, motions to dismiss, plea to jurisdiction, motions to transfer venue, motions for voluntary dismissal/ nonsuits, post-verdict motions, special appearances, and motions involving service of process. Failure to comply may result in the Court passing the hearing.

Summary: A detailed certificate of conference is required for all motions except enumerated types; noncompliance may cause the court to pass the hearing.

The quote is in the court's document. The summary is not checked yet.CRITICAL?

Applies to

Discovery motion

Must include

certificate of conference ?

The Court requires compliance with Texas Rule of Civil Procedure 191.2, which states as follows: “Parties and their attorneys are expected to cooperate in discovery and to make any agreements reasonably necessary for the efficient disposition of the case. All discovery motions or requests for hearings relating to discovery must contain a certificate by the party filing the motion or request that a reasonable effort has been made to resolve the dispute without the necessity of Court intervention and the effort failed.”

Summary: Discovery motions and discovery hearing requests must include a certificate stating a reasonable effort to resolve the dispute was made and failed.

The quote is in the court's document. The summary is not checked yet.CRITICAL?

Applies to

Default judgment motion ?

Must include

certificate of service

All motions for default are heard in an oral hearing only. Default motions are heard at 9:30 a.m. (with live testimony) and 9:45 a.m. (all others) on Monday. A certificate of service providing proof of service of a notice of hearing to the non-movant(s) must accompany all Default motions. A separate certificate of last known address and a proper non-military service affidavit must be attached to the motion. A non-military verification may be obtained by visiting the Defense Manpower Data Center’s (DMDC) Military Verification service at https://scra.dmdc.osd.mil.

Summary: Default judgment motions require an oral hearing, proof of service of the hearing notice, a certificate of last known address, and a non-military service affidavit.

The quote is in the court's document. The summary is not checked yet.CRITICAL?

Applies to

Motion response

Must include

proposed order

E-file motion responses at least 48-hours before the hearing and include a proposed order.

Summary: The motion response must include a proposed order with the e-filing.

The quote is in the court's document. The summary is not checked yet.CRITICAL?

Applies to

Notice of oral hearing

Must include

certificate of service ?

Once you obtain a hearing date you are required to file a Notice of Oral Hearing and serve it on all counsel or pro se parties.

Summary: After obtaining a hearing date, a party must file a Notice of Oral Hearing and serve it on all counsel and pro se parties.

The quote is in the court's document. The summary is not checked yet.CRITICAL?

Applies to

Motion

Must include

certificate of conference

A certificate of conference is required on all motions, pleas and special exceptions except: Summary Judgments, Default Judgments, Agreed Judgments, Motions for voluntary dismissal or non-suit, Post-verdict motions; or Motions involving service of citation.

Summary: A certificate of election is required on all motions, pleas, and special exceptions except for specifically enumerated categories.

The quote is in the court's document. The summary is not checked yet.CRITICAL?

Applies to

Certificate of conference

The movant must confer person-to-person with opposing counsel before the Court will consider a motion that requires a conference. The Court will pass motions that do not have a certificate stating (1) that the movant has actually talked to opposing counsel, or (2) why counsel have not been able to discuss the motion. A certificate of conference stating that you sent a letter or email to opposing counsel and received no response is not a proper certificate of conference.

Summary: Persons preparing a certificate of conference must confer personally with opposing counsel or explain why they could not; sending a letter/email and receiving no response is insufficient.

The quote is in the court's document. The summary is not checked yet.CRITICAL?

Applies to

Motion and response

Must include

proposed order

File proposed orders with all motions and responses.

Summary: Proposed orders must be filed with every motion and with every response to a motion.

The quote is in the court's document. The summary is not checked yet.CRITICAL?

Applies to

Discovery motion ?

The complaining party should file a motion containing: A brief description of the dispute; The date, time, and place doing the discussions have had out-of-court discovery; The names of counsel participating in the discussions; and A copy or verbatim reproduction of the discovery requests and responses at issue.

Summary: Discovery complaints must be filed by motion containing specified identification of the dispute, the parties' out-of-court discovery discussions, all counsel participating, and the discovery requests and responses.

The quote is in the court's document. The summary is not checked yet.CRITICAL?

Applies to

Motion or notice nonsuit ?

When a lawsuit involves a minor, any notice or motion for nonsuit must be filed without prejudice.

Summary: A notice or motion for non-suit in a case involving a minor must be filed without prejudice.

The quote is in the court's document. The summary is not checked yet.CRITICAL?

Applies to

Agreed motion and order gal appointment ?

Must include

proposed order ?

A Guardian Ad Litem will be required for all settlements involving minor children. The parties are to submit an Agreed motion and order for appointment of a Guardian Ad Litem.

Summary: All settlements involving minor children require a Guardian Ad Litem and the parties must submit an agreed motion and order for the GAL's appointment.

The quote is in the court's document. The summary is not checked yet.CRITICAL?

Applies to

Notice of hearing

Must include

certificate of service

If your matter is opposed and you do not schedule your hearing and file a notice of hearing with a certificate of service, the court will not make a ruling.

Summary: Opposed matters require scheduling a hearing and filing a notice of hearing with a certificate of service; otherwise the court will not rule.

The quote is in the court's document. The summary is not checked yet.WARNING?

Applies to

Motion

Your requests to the court should be made in a written motion.

Summary: Requests to the court must be made in a written motion.

The quote is in the court's document. The summary is not checked yet.WARNING?

Applies to

Business card

Identify yourself to the Judge and the court reporter before a hearing begins. Provide a business card with your name, correct address, phone number, fax number and e-mail address. Also include party representation.

Summary: Attorneys must identify themselves to the Judge and court reporter before a hearing and provide a business card with contact details and party representation.

The quote is in the court's document. The summary is not checked yet.WARNING?

Applies to

Deposition designations ?

Page/line designations of deposition testimony, along with a non-condensed copy of the transcript, are to be furnished to the court reporter prior to the offer. When one person is reading from written deposition testimony, the reader must say “Question” prior to reading each question and “Answer” prior to reading each answer.

Summary: Deposition page/line designations and a non-condensed transcript copy must be furnished to the court reporter before the offer, and readers must announce 'Question' and 'Answer' when reading deposition testimony.

The quote is in the court's document. The summary is not checked yet.WARNING?

Civil cases

Applies to

Guardian ad litem application ?

Those wishing to be included in the Court’s list must submit a written request with a complete resume that details the nature of the applicant’s experience as a civil trial practitioner. Special capabilities, such as fluency in languages other than English, financial background, and the like, should also be listed.

Summary: Applicants for the guardian ad litem list must submit a written request with a complete resume detailing their civil trial experience and any special capabilities.

The quote is in the court's document. The summary is not checked yet.WARNING?

Civil cases

Applies to

Guardian ad litem application ?

Applicants must also affirm that professional liability coverage is in effect and will remain current.

Summary: Guardian ad litem applicants must affirm that professional liability coverage is in effect and will remain current.

The quote is in the court's document. The summary is not checked yet.WARNING?

Civil cases

Applies to

Motion

Both parties must agree to the request and file a motion with the court.

Summary: Both parties must agree to a preferential setting request and file a motion with the court.

The quote is in the court's document. The summary is not checked yet.WARNING?

Civil cases

Applies to

Motion

The Motion to Request a Preferential Setting must include the basis for the preferential setting (i.e out of town witnesses, will take two (2) weeks or longer to try.)

Summary: The Motion to Request a Preferential Setting must include the basis for the preferential setting (e.g., out-of-town witnesses, trial will take two weeks or longer).

The quote is in the court's document. The summary is not checked yet.WARNING?

Civil cases

Applies to

Motion ?

Counsel understands that by requesting a preferential setting, they agree to the following:To waive all vacations letters for that time period.

Summary: By requesting a preferential setting, counsel agrees to waive all vacation letters for that time period.

The quote is in the court's document. The summary is not checked yet.WARNING?

Applies to

Exhibits

PLEASE HAVE ALL EXHIBITS PREMARKED BEFORE TRIAL AND A COPY OF YOUR EXHIBIT LIST FOR THE JUDGE, THE COURT REPORTER AND OPPOSING COUNSEL BESIDES THE ONE FILED IN YOUR PRETRIAL ORDER.

Summary: All exhibits must be premarked before trial and exhibit list copies provided to the judge, court reporter, and opposing counsel.

The quote is in the court's document. The summary is not checked yet.WARNING?

Applies to

Certificate of conference

The certificate of conference should include a detailed statement of the movant's efforts to resolve the issues in the motion with opposing counsel/party prior to filing the motion. 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 and before the hearing on the motion.

Summary: Certificates of conference must detail the movant's resolution efforts, describe attempts to communicate when opposing counsel could not be reached, and be supplemented after actual conferrence.

The quote is in the court's document. The summary is not checked yet.WARNING?

Applies to

Certificate of conference ?

The Court does not consider the following statements, or the like, to comply with the Rule: “Sent a letter…did not get a response” “Left a message…don’t know if the other side agrees or disagrees.” “The other side won’t return my phone calls.” “I have attempted to resolve this matter by agreement but was unable to do so.”

Summary: Vague statements about unreturned calls or unanswered letters do not satisfy the certificate of conference requirement.

The quote is in the court's document. The summary is not checked yet.WARNING?

Applies to

Motion for substituted service

Must include

proposed order ?

Motions for substituted service are submitted to the Court for consideration without the need for a hearing. The motion should include an affidavit (a) detailing all efforts taken to verify that the defendant actually lives or works at the subject address, (b) multiple attempts of service at different times of day with the specific dates and times, (c) the identity of person(s) present at the subject address and what was said, (d) the identity of the owners of any cars in the driveway or other indications that defendant resides at the subject address; (e) in the proper circumstances, whether the technology actually belongs to the defendant and whether the defendant regularly uses or recently used the technology. Motions should include the attached form order for substituted service.

Summary: Substituted service motions require a detailed affidavit and the court's attached form order, and are decided without a hearing.

The quote is in the court's document. The summary is not checked yet.WARNING?

Applies to

Severance motion ?

Severances: The party requesting the severance must specifically list all pleadings to be included in the severance order to be transferred to the new file.

Summary: A party seeking a severance must specifically list all pleadings to be transferred.

The quote is in the court's document. The summary is not checked yet.WARNING?

Applies to

Discovery motion

All discovery motions should specify each specific discovery response at issue and include a copy of the response(s) at issue as sub-documents when or state verbatim as a request and answer in the body of your motion.

Summary: Discovery motions must identify every specific discovery response at issue, copying the responses as separate sub-documents or quoting them verbatim.

The quote is in the court's document. The summary is not checked yet.WARNING?

Applies to

Sanctions motion ?

Sanctions should not be requested unless the opponent has violated a previous order and engaged in particularly egregious behavior.

Summary: Sanctions requests should only be made when a prior order has been violated by egregious conduct.

The quote is in the court's document. The summary is not checked yet.WARNING?

Applies to

Special setting request letter ?

In the event that you are unable to secure a hearing date as soon as necessary on the Court's regular oral hearing docket, or if you require a special setting, please file a letter with the Court, and serve it on all parties, requesting a special setting with alternative dates that are convenient for all parties and the date by which you are requesting the matter be heard by the Court. Please send a courtesy copy of the letter to the Clerk who will then give it to that judge for review.

Summary: A request for a special setting must be made by letter filed with the Court, served on all parties, stating alternative dates and deadline, with a courtesy copy to the Clerk.

The quote is in the court's document. The summary is not checked yet.WARNING?

Applies to

Corporate withdrawal notice ?

In addition to the items listed above, if the client is a corporation, the attorney must notify the client that the corporation cannot proceed pro se and that if the corporation has not obtained new counsel within 30 days a default judgment may be entered against it if a defendant, or its claims dismissed if a plaintiff.

Summary: For withdrawing from a corporate client, the notice must state the corporation cannot proceed pro se and after 30 days may face default or dismissal.

The quote is in the court's document. The summary is not checked yet.WARNING?

Applies to

Motion in limine

Motions in Limine should be specific to the case. Do not duplicate items in your motions in limine. Our motion limited to only those items specific to the facts and circumstances in your case.

Summary: A motion in limine must be tailored to the specific case and not duplicate the standing order in limine.

The quote is in the court's document. The summary is not checked yet.WARNING?

Applies to

Motion

Your requests to the court should be made in a written motion.

Summary: Requests to the court must be made in a written motion.

The quote is in the court's document. The summary is not checked yet.WARNING?

Applies to

Agreed motion ?

Must include

certificate of conference

Agreed or unopposed motions should be titled as such and signed by all parties or include a Certificate of Conference.

Summary: Agreed or unopposed motions must be appropriately titled and must be signed by all parties or include a Certificate of Conference.

The quote is in the court's document. The summary is not checked yet.WARNING?

Applies to

Proposed continuance order ?

The proposed order granting the continuance shall provide a space for the new trial date to be inserted by the Court.

Summary: The proposed continuation order must provide a blank space for the Court to insert the new trial date.

The quote is in the court's document. The summary is not checked yet.WARNING?

Applies to

Motion for continuance

If the parties would like to amend the docket control order in addition to continuing the trial date, please note your request in the Motion for Continuance and include the statement that a new scheduling order shall be issued by the Court in the proposed order. Alternatively, an amended scheduling order may be submitted.

Summary: A continuance request that also asks to amend the docket control order must state in the motion and proposed order that a new scheduling order will be issued, or an amended scheduling order may be submitted.

The quote is in the court's document. The summary is not checked yet.WARNING?

Applies to

Proposed order

When submitting a proposed order, you must include a cover letter and indicate whether the proposed order is agreed as to form.

Summary: Each proposed order must be accompanied by a cover letter stating whether the order is agreed to as to form.

The quote is in the court's document. The summary is not checked yet.WARNING?

Applies to

Discovery proposed order ?

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

Summary: Discovery proposed orders must list each discovery issue separately to enable specific rulings.

The quote is in the court's document. The summary is not checked yet.WARNING?

Applies to

Motion for default judgment

When proving damages in a motion for default judgment, show the court how you calculated the figure and provide evidence to support your calculation.

Summary: In a default judgment motion, the movant must explain the damages calculation and provide supporting evidence.

The quote is in the court's document. The summary is not checked yet.WARNING?

Applies to

Default judgment fee affidavit ?

When proving attorney's fees in a motion for default judgment, in your affidavit provide the court with evidence to support your claim for attorney's fees. At a minimum you should show (1) your experience, (2) the work you did on the lawsuit, (3) how long it took you to do it and (4) your hourly rate.

Summary: In a default judgment motion, the fee affidavit must at minimum show experience, work performed, time spent, and hourly rate.

The quote is in the court's document. The summary is not checked yet.WARNING?

Civil cases

Applies to

Motion

Motions and responses should identify specific deposition testimony relied upon to support a position, rather than simply attaching a deposition.

Summary: Motions and responses must identify specific deposition testimony rather than merely attaching depositions.

The quote is in the court's document. The summary is not checked yet.WARNING?

Civil cases

Applies to

Proposed order

Proposed orders granting summary judgments should include all relief requested.

Summary: Proposed orders granting summary judgment must include all relief requested.

The quote is in the court's document. The summary is not checked yet.WARNING?

Civil cases

Applies to

Motion

Motions should show how damages are calculated and provide supporting evidence.

Summary: Motions must explain how damages are calculated and provide supporting evidence.

The quote is in the court's document. The summary is not checked yet.WARNING?

Applies to

Notice of hearing

The court has also established a permanent zoom link which should be put in notices of hearings and provided to parties/lawyers/witnesses who are part of the hearing - permanent zoom link.

Summary: Notices of hearings must include the court's permanent Zoom link.

The quote is in the court's document. The summary is not checked yet.INFO?

Applies to

Motion

Unopposed/agreed motions, non-suits, motions for substitute service do not require setting a hearing.

Summary: Unopposed/agreed motions, non-suits, and motions for substitute service do not require setting a hearing.

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

Civil cases

Applies to

Certificate of conference

Certificates of conference must state how and when parties have conferred on the matters on which relief is sought, and whether the relief is opposed, agreed, or agreed in part.

Summary: Certificates of conference must state how and when parties conferred and whether relief is opposed or agreed.

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

Civil cases

Applies to

Motion

Must include

proposed order

All motions and responses must have a proposed order. The Court may pass hearings on motions filed without a proposed order. All motions should have their own proposed order (Please do not combine multiple motions into one order). The proposed order should include the exact title of the motion being considered.

Summary: All motions and responses require a proposed order; each motion should have its own proposed order containing the exact motion title.

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

Civil cases

Applies to

Motion

Must include

proposed order ?

The parties are to submit an agreed motion and order for appointment of a Guardian Ad Litem.

Summary: Parties must submit an agreed motion and order for appointment of a Guardian Ad Litem for minor settlements.

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

Civil cases

Applies to

Pretrial order ?

All parties must comply with the order prior to the pretrial conference.

Summary: All parties must comply with the standing Pretrial Order prior to the pretrial conference.

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

Civil cases

Applies to

Trial documents

All motions and trial documents need exchanged by parties, e-filed and submitted to the court before your pretrial conference. This includes, but is not limited to: live pleadings; witness lists (with estimated time for examination and cross-examination of each); exhibit lists (including copies of exhibits and any objections); motions in limine and objections; deposition extracts and objections; and proposed jury charges.

Summary: Before the pretrial conference, parties must exchange, e-file, and submit all motions and trial documents, including pleadings, witness lists, exhibit lists, in limine motions, deposition extracts, and proposed jury charges.

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

Applies to

Proposed order ?

Orders on motions to withdraw must include contact information for the pro se party.

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

Applies to

Motion ?

If the withdrawing attorney represents a corporation, she/he must notify the corporation that: Corporations cannot proceed pro se in Texas courts; and That if the corporation has not obtained counsel within 30 days of the order of withdrawal, either its claims may be dismissed if it is the plaintiff or their pleadings may be struck and a default judgment may be entered if it is the defendant.

Summary: A withdrawing attorney representing a corporation must notify the corporation that it cannot proceed pro se and of the consequences of not obtaining counsel within 30 days.

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

Civil cases

Applies to

Proposed findings conclusions ?

Be prepare and exchange proposed findings of fact and conclusions of law with all counsel and provide them to the judge. In addition, prepare a proposed form of judgment.

Summary: For bench trials, parties must exchange proposed findings of fact and conclusions of law and provide a proposed judgment.

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

Applies to

Motion ?

Certificates of conference must state how and when parties have conferred on the matters on which relief is sought, and whether the relief is opposed, agreed, or agreed in part.

Summary: A certificate of conference must state how and when parties conferred and whether the relief is opposed, agreed, or agreed in part.

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

Civil cases

Applies to

Motion

The following motions will be presented to the Judge upon filing and may not need to be set for an oral hearing. If an oral hearing is needed, the Court will contact you. All other motion must be set for either an oral or submission hearing.

Summary: 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.

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

Civil cases

Applies to

Motion ?

Attach a copy of the pleading you are excepting to (unless the exception is only to the amount of damages sought) or state verbatim the paragraph you except to in the pleading.

Summary: Special exceptions must attach the excepted pleading or state the excepted paragraph verbatim.

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

Civil cases

Applies to

Motion ?

Nonsuits are presented to the Judge upon filing without need for a hearing with the exception of cases involving minors. These must be set for an oral hearing. If the minor has reached the age of majority, an affidavit stating so must be filed with the nonsuit and a hearing is not required.

Summary: Nonsuits involving minors require an oral hearing unless an affidavit states the minor has reached the age of majority.

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

Civil cases

Applies to

Motion to withdraw as attorney of record ?

Must include

certificate of conference

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.

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

Civil cases

Applies to

Discovery motion ?

Must include

certificate of conference

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.

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

Civil cases

Applies to

Default judgment motion and proposed judgment ?

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.

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

Civil cases

Applies to

Default judgment filing ?

A Certificate of Last Known Address must be filed.

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

Civil cases

Applies to

Default judgment request for damages or fees ?

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.

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

Civil cases

Applies to

Summary judgment motion ?

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.

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

Civil cases

Applies to

Deposition designations ?

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.

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

Civil cases

Applies to

Minor settlement guardian ad litem appointment ?

Must include

proposed order

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.

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

Civil cases

Applies to

Motion

Must include

proposed order

All motions and responses must be filed with a corresponding order. The Court may pass motions filed without proposed orders.

Summary: Motions and responses must include a proposed order; motions without proposed orders may be passed.

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

Civil cases

Applies to

Summary judgment order ?

Proposed orders should include total damages and attorneys fees. The motion must contain evidence to support the amounts contained in the judgment.

Summary: Proposed orders for summary judgments must include total damages and attorney's fees; the motion must contain supporting evidence.

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

Civil cases

Applies to

Jury charge ?

The parties must file their proposed charge and must provide the court with a copy on a flash drive.

Summary: Parties must file the proposed jury charge and provide a copy to the court on a flash drive.

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

Civil cases

Applies to

Notice of appearance

The Court will not proceed with default judgment if the party appears at the hearing on default judgment. However, the party must complete a notice of appearance and answer form at the time of the hearing so that the matter can be set for trial.

Summary: If a party appears at a tax default judgment hearing, the Court will not proceed; the party must complete a notice of appearance and answer form.

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

Civil cases

Applies to

Opposition ?

Must include

proposed order ?

Please include an order denying your opponent’s motion.

Summary: A written response must include a proposed order denying the opponent's motion.

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

Civil cases

Applies to

Motion

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.

Summary: Relief will be denied without further consideration if a motion relies on nonexistent, fabricated, or hallucinated citations.

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

Civil cases

Applies to

Settlement involving minor children ?

Must include

proposed order

The parties shall file an Agreed Motion for Appointment of Guardian Ad Litem and a proposed Order Appointing Guardian Ad Litem.

Summary: The parties must file an agreed motion to appoint a Guardian Ad Litem and a proposed appointment order.

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

Civil cases

Applies to

Default judgment motion ?

A Non-Military Affidavit that complies with recent amendments to the Soldiers and Sailors Relief Act must be submitted with the motion.

Summary: A compliant Non-Military Affidavit must accompany the default judgment motion.

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

Civil cases

Applies to

Notice of Oral Hearing ?

The notice must state the exact title of each motion to be heard.

Summary: A Notice of Oral Hearing must give the exact title of every motion to be heard.

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

Civil cases

Applies to

Summary judgment motion ?

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

Summary: A summary judgment movant’s oral-hearing request must appear in the motion title.

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

Civil cases

Applies to

Summary judgment response ?

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

Summary: A summary judgment non-movant’s oral-hearing request must appear in the response title.

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

Civil cases

Applies to

Emergency motion ?

The motion must also reflect that notice has been provided to all opposing counsel or self-represented parties, or must explain with specificity why notice could not be given.

Summary: An emergency motion must state that notice was given to opposing counsel or self-represented parties, or specifically explain why notice could not be given.

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

Civil cases

Applies to

Proposed order on first continuance ?

Must include

proposed order

The proposed order shall include a blank for the Court to insert the new trial date.

Summary: A proposed order on a first continuance must leave a blank for the Court to insert the new trial date.

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

Civil cases

Applies to

Continuance or reset motion

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.).

Summary: Every continuance or reset motion must identify its sequence number, whether agreed, unopposed, or opposed.

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

Civil cases

Applies to

Default judgment submission ?

Please submit the proper non-military affidavit by visiting the Defense Manpower Data Center’s (DMDC) Military Verification service at https://scra.dmdc.osd.mil.

Summary: Submit the proper non-military affidavit using the Defense Manpower Data Center Military Verification service.

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

Civil cases

Applies to

Default judgment motion and proposed judgment ?

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-judgment motion and proposed judgment must identify whether the judgment is final or interlocutory.

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

Civil cases

Applies to

Severance motion and order ?

All motions AND orders for severance MUST contain the following:

Summary: Severance motions and orders must include each of the specified case and transfer details.

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

Civil cases

Applies to

Severance motion and order ?

New case number, court number, case type and new style name;

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

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

Civil cases

Applies to

Severance motion and order ?

Reference the parties in the new suit;

Summary: A severance motion and order must identify the parties in the new suit.

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

Civil cases

Applies to

Severance motion and order ?

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);

Summary: A severance motion and order must list the original pleadings to be transferred and each pleading’s document type, activity date, page count, and image number.

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

Civil cases

Applies to

Severance motion and order ?

Indicate attorney name, address and bar number to whom costs for the severance are to be assessed; and

Summary: A severance motion and order must identify the attorney name, address, and bar number for assessment of severance costs.

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

Civil cases

Applies to

Severance motion ?

This should be expressly stated one way or the other in the motion for severance.

Summary: The severance motion must expressly state whether the newly severed matter is interlocutory or final and appealable.

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

Civil cases

Applies to

Rule 106 affidavit ?

Efforts taken to verify that defendant actually lives or works at the subject address;

Summary: The Rule 106 affidavit must describe efforts to verify that the defendant lives or works at the address.

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

Civil cases

Applies to

Rule 106 affidavit ?

Each attempt at service, with date(s) and time(s)A total of 6 attempts are required. Must have at least 1 before 7:30 AM and 2 after 6:00 PM.

Summary: The Rule 106 affidavit must list each service attempt with its date and time; six attempts are required, including at least one before 7:30 AM and two after 6:00 PM.

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

Civil cases

Applies to

Rule 106 affidavit ?

Identity of persons who were present at the subject address and what was said; and

Summary: The Rule 106 affidavit must identify persons present at the address and state what was said.

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

Civil cases

Applies to

Rule 106 affidavit ?

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.

Summary: The Rule 106 affidavit must include a public-record or similar database printout confirming the person resides at the service address.

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

Civil cases

Applies to

Continuance or reset motion

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.).

Summary: Every continuance or reset motion must identify its sequence number, whether agreed, unopposed, or opposed.

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

Civil cases

Applies to

Motion and proposed order to withdraw

All motions AND proposed orders to withdraw as attorney of record MUST contain the following:

Summary: A motion and proposed order to withdraw as attorney of record must include the specified client-notice, consent, contact, and hearing-right information.

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

Civil cases

Applies to

Motion and proposed order to withdraw ?

An indication that the motion to withdraw and notice of the hearing or notice of submission was provided to the client, including evidence of mailing the motion to the client;

Summary: A withdrawal motion and order must indicate that the motion and hearing or submission notice were provided to the client and include evidence that the motion was mailed.

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

Civil cases

Applies to

Motion and proposed order to withdraw ?

An indication of whether or not the client consents to the motion;

Summary: A withdrawal motion and order must state whether the client consents.

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

Civil cases

Applies to

Motion and proposed order to withdraw ?

The last known mailing address, email, phone and fax number of client; and

Summary: A withdrawal motion and order must provide the client’s last known mailing address, email, phone number, and fax number.

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

Civil cases

Applies to

Motion and proposed order to withdraw ?

Notice to client that client has the right to appear at the hearing to object to the motion or file a response prior to the submission of the motion;

Summary: The client must be notified of the right to appear and object at the hearing or file a response before submission.

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

Civil cases

Applies to

Motion to withdraw as attorney of record ?

Must include

certificate of conference

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.

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

Civil cases

Applies to

Case conduct ?

Throughout the pendency of a case, the parties, all counsel, and their agents or representatives shall comply with the Texas Rules of Civil Procedure, the Texas Disciplinary Rules of Professional Conduct, and the Texas Lawyers’ Creed – A Mandate for Professionalism (as applicable).

Summary: Throughout a case, parties, counsel, agents, and representatives must comply with the stated Texas procedural and professional-conduct rules, as applicable.

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

Civil cases

Applies to

Bench trial documents ?

Counsel shall file a Findings of Fact and Conclusions of Law and a Final Judgment with the Court prior to trial.

Summary: Counsel must file Findings of Fact and Conclusions of Law and a Final Judgment before a bench trial.

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

Civil cases

Applies to

Motion to retain

Must include

proposed order

A Motion to Retain and Proposed Order must be filed to retain the set case for dismissal on the Court's docket.

Summary: To retain a case on the DWOP docket, a motion to retain and proposed order must be filed.

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

Civil cases

Applies to

Motion to retain

Must include

proposed order

If a judgment/non-suit has not been filed at the time of DWOP and counsel would like to maintain the case on the docket, a Motion to Retain must be filed with the Court. A Proposed Order must be filed in order for a Motion to Retain to be granted and avoidance of DWOP.

Summary: To avoid DWOP after settlement, a motion to retain and proposed order must be filed.

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

Civil cases

Applies to

Motion for emergency hearing ?

If only one side feels it is an emergency, e-file a motion for emergency/expedited hearing.

Summary: If only one side considers it an emergency, e-file a motion for emergency hearing.

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

Civil cases

Applies to

Motion

Must include

certificate of conference

A certificate of conference is required for all motions, pleas, and special exceptions except for: dispositive motions, including motions for summary judgment; default judgments; motions for voluntary dismissal or non-suit; and motions involving service of citations.

Summary: A certificate of conference is required for all motions, pleas, and special exceptions, with specific exceptions for dispositive motions, default judgments, voluntary dismissals/non-suits, and service-of-citation motions.

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

Civil cases

Applies to

Proposed order ?

Must include

proposed order ?

At least 24 hours prior to the time of the hearing, the parties are to present the proposed Judgment, as well as the Supreme Court ad litem fee report.

Summary: At least 24 hours before the minor settlement hearing, parties must present the proposed Judgment and the Supreme Court ad litem fee report.

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

Civil cases

Applies to

Motion

Must include

certificate of service ?

Rule 106 Motions can be submitted to the Court without the need for an oral hearing but 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 and time; identity of persons who were present at the subject address and what was said; and identity of cars in driveway, other indications that defendant resides at the subject address, or other evidence that service as proposed is likely to give the defendant actual notice of the lawsuit.

Summary: Rule 106 motions may be submitted without an oral hearing but must include an affidavit with specified service details.

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

Civil cases

Applies to

Trial notebook

The parties must prepare, exchange and bring to the pretrial conference, a Trial Notebook that contains: live pleadings; witness lists (with estimated time for examination and cross-examination of each); exhibit lists (including copies of exhibits and any objections); motions in limine and objections; deposition excerpts and objections; and proposed jury charges.

Summary: Parties must prepare, exchange, and bring a Trial Notebook containing live pleadings, witness lists, exhibit lists, motions in limine, deposition excerpts, and proposed jury charges.

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

Civil cases

Applies to

Motion

Must include

proposed order ?

If a party would like to request permission from the Court to have a witness appear for trial via Zoom, a motion requesting leave for this purpose should be filed and set for oral hearing. The Motion for Leave must be agreed, and must include a sworn statement from the attorney presenting the witness that: They have ensured that the witness has available electronic equipment sufficient to host such testimony and that the attorney and witness have personally tested the equipment to ensure it works and everyone involved knows how to use the equipment; The witness will be testifying in a neutral setting with no room decoration within view of the camera; The witness will be the only person in the room; and A complete set of all exhibits (or select exhibits as agreed upon by all counsel in cases with more than 50 total exhibits), in hard copy, have been delivered to the witness, and that the witness will have all exhibits available for testimony.

Summary: To request remote testimony via Zoom, file an agreed motion for leave set for oral hearing, including a sworn statement with specific equipment, setting, and exhibit requirements.

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

Civil cases

Applies to

Rule 106 motion

Parties requesting an Order for Substituted Service under Rule 106 should use the court’s suggested form: 190TH Order Granting Rule 106 Substitute Service.docx. Rule 106 Motions can be submitted to the Court without the need for an oral hearing but 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 and time; identity of persons who were present at the subject address and what was said; and identity of cars in driveway or other indications that defendant resides at the subject address.

Summary: Rule 106 motions may be submitted without oral hearing but must use court's form and include affidavit with required service attempts information.

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

Civil cases

Applies to

Courtesy copy

Must include

proposed order

Also include a copy of the proposed order, latest live pleading and answer, latest DCO, and any legal authority, with any courtesy copy provided to the court.

Summary: Courtesy copies must include the proposed order, latest live pleading and answer, latest DCO, and any legal authority.

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

Civil cases

Applies to

Minor settlement hearing ?

At the time of the hearing, the parties are to present the proposed Judgment, as well as the Supreme Court ad litem fee report.

Summary: At the minor settlement hearing, parties must present the proposed Judgment and the Supreme Court ad litem fee report.

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

Civil cases

Applies to

Motion to retain ?

Must include

proposed order

Please e-file a proposed Order to accompany your Motion.

Summary: A proposed order must be e-filed with a Motion to Retain.

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

Applies to

Motion ?

A certificate of conference stating that you sent a letter or email to opposing counsel and received no response is not a proper certificate of conference.

Summary: A certificate stating only that a letter/email was sent with no response is not a proper certificate of conference.

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

Applies to

Motion

The Court will pass motions that do not have a certificate stating (1) that the movant has actually talked to opposing counsel, or (2) why counsel have not been able to discuss the motion.

Summary: The Court will pass (not consider) motions whose certificate does not state either that the movant talked to opposing counsel or why counsel could not discuss the motion.

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

Applies to

Proposed order ?

Orders on motions to withdraw also must include contact information for the pro-se litigant.

Summary: Orders on motions to withdraw must include contact information for the pro se litigant.

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

Civil cases

Applies to

Motion ?

Sanctions should not be requested unless the opponent has violated a previous order. Instead, ask for reimbursement of your costs in the form of attorney fees.

Summary: Sanctions should only be requested after a previous order violation; otherwise request attorney fees as cost reimbursement.

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

Civil cases