Harris County District Courts Pre-Motion Conference Requirements

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

Civil cases

All summary judgment motions must be set for oral hearing on the law day docket within 30 days of filing.

ALL Summary Judgment Motions MUST be set for an ORAL HEARING ONLY and placed on our LAW DAY DOCKET within 30 days of filing.

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

Civil cases

Oral hearing is required only for expedited foreclosure default judgments; other default judgments may be set for submission.

An oral hearing is required on expedited foreclosure default judgments only. All other default judgments can be set for submission.

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

Civil cases

HOA default judgment motions based on unpaid assessments or deed restriction violations must be set for an oral hearing; board member or property manager need not be present.

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.

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

Civil cases

All show cause matters must be heard orally.

All Show Causes must be done by oral hearing.

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

Parties must confer with opposing counsel before filing all motions except for an enumerated list of exempt motion types.

You are required to confer with opposing counsel prior to filing all motions except for motions for summary judgment, motions to dismiss, pleas to the jurisdiction, motions to transfer venue, motions for voluntary dismissal/nonsuit, post-verdict motions, motions involving service of process or default judgments.

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

The movant must confer person-to-person with opposing counsel before the Court will consider a motion that requires a conference.

The movant must confer person-to-person with opposing counsel before the Court will consider a motion that requires a conference.

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

Emergency hearings are granted only if the parties have conferred about the matter.

An emergency hearing will not be granted unless the parties have conferred about the matter.

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

All cases must mediate before a temporary injunction hearing is heard.

The 270th REQUIRES ALL cases to mediate before the Temporary Injunction is heard.

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

All cases must be mediated before trial.

All cases are required to be mediated before trial.

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

Civil cases

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

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

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

Civil cases

Parties must confer on all discovery motions before the hearing and be prepared to discuss those efforts with the Court.

The parties should conference on all discovery motions prior to a hearing and be prepared address these efforts with the Court.

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

Civil cases

Before the Court considers a motion requiring a conference, the movant must confer directly and person-to-person with opposing counsel.

The movant must confer directly, person-to-person, with opposing counsel before the Court will consider any motion requiring a conference.

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

Civil cases

Motions to compel and other discovery-dispute motions must be set on the oral hearing docket.

All motions to compel, and any motion related to discovery disputes, must be set on the oral hearing docket.

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

Civil cases

A default judgment seeking unliquidated damages requires an oral hearing, which is set by contacting the Clerk after filing the motion.

Default judgments seeking unliquidated damages require an oral hearing. Contact the Clerk to set the hearing after filing the motion.

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

Civil cases

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

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

Checked and corrected to match the court's document on Oct 3, 2026CRITICAL

Civil cases

Motions to withdraw must be set for oral hearing unless they strictly comply with Rule 10 and are signed by all parties and attorneys of record.

All motions to withdraw as counsel must be set on the Court’s oral hearing docket unless the motion strictly complies with Texas Rule of Civil Procedure 10 and is signed by all parties and all attorneys of record.

Checked and corrected to match the court's document on Oct 3, 2026CRITICAL

Civil cases

Contested motions to withdraw must always be set for oral hearing and will be granted only when absolutely necessary.

Contested motions to withdraw must be set for oral hearing in all circumstances and will be granted only when absolutely necessary.

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

Civil cases

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

No motion will be set for oral hearing without a time estimate.

Checked and corrected to match the court's document on Oct 3, 2026CRITICAL

Civil cases

A summary judgment motion cannot be passed; the party must proceed with or withdraw it.

Passing a motion for summary judgment is not permitted under Rule 166a, as amended. A party must either proceed on the motion or withdraw it.

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

Civil cases

Parties must confer before filing a discovery motion to attempt resolution without court intervention.

The Court expects that parties will make every effort to resolve all discovery issues without court intervention. Conferences shall occur prior to the filing of the discovery motion.

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

Civil cases

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

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

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

Civil cases

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

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

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

Civil cases

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

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

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

Civil cases

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

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

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

Civil cases

Do not request sanctions unless a prior court order has been violated.

Sanctions should not be requested absent a violation of a prior court order.

Checked and corrected to match the court's document on Oct 3, 2026WARNING

Civil cases

A no-evidence summary judgment motion filed before discovery ends will likely be denied without prejudice.

Any no-evidence motion for summary judgment filed before the discovery period has elapsed will likely be DENIED without prejudice.

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

Civil cases

Parties may amend Docket Control Order deadlines, except joinder, pretrial conference, or trial-setting dates, by Rule 11 agreement or motion for leave.

To amend any deadline contained in the Docket Control Order (other than joinder, pretrial conference, or trial setting), the parties may proceed by Rule 11 agreement or by filing a motion for leave of court.

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

Civil cases

Default judgments are placed on the submission docket unless unliquidated damages must be proved up.

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

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

Civil cases

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

Motions for withdrawal of counsel must be set on the oral hearing docket, unless the client has agreed to the withdraw and signed an acceptance of the attorney’s notice letter.

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

Civil cases

The first Verified Motion to Retain may be filed without a hearing; subsequent motions to retain must be set for oral hearing.

The first Verified Motion to Retain does not need to be set on an oral hearing or submission docket. It should be filed and will be considered by the Court. Any subsequent motion to retain must be set for an oral hearing.

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

Civil cases

Preferential trial settings may be requested by motion, which must be set for an oral hearing.

Preferential settings are available in special circumstances and may be requested by motion. Such motions must be set for an oral hearing to be considered by the Court.

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

Civil cases

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

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

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

Civil cases

Unless another procedure applies, agreed or unopposed motions need not be set on an oral hearing or submission docket.

Unless otherwise specified herein, agreed or unopposed motions are not required to be set on the oral hearing or submission docket.

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

Civil cases

Default judgments seeking liquidated damages may be set on the submission docket.

Default judgments seeking liquidated damages may be set on the submission docket.

Checked and corrected to match the court's document on Oct 3, 2026INFO

Civil cases

Motions for substitution may be set on the submission docket.

Motions for substitution may be set on the Court’s submission docket.

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

Civil cases

Agreed and unopposed motions need not be placed on the oral-hearing or submission docket.

Agreed or unopposed motions do not have to be placed on the court’s oral hearing or submission docket.

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

Civil cases

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

These motions are expeditiously presented to Judge Aston without the necessity of a hearing (this includes unopposed motions for continuance).

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

Failure to actually confer with the other side or adequately explain why, after multiple attempts, you were unable to confer before the hearing or submission date may result in your motion being removed from the docket.

Summary: Failure to actually confer or adequately explain unsuccessful attempts may result in the motion being removed from the docket.

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

Civil cases

@ 2:00 Defaults (appearance required)

Summary: Default judgment hearings are set for Tuesdays at 2:00 PM and require an appearance.

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

Civil cases

@ 3:00 Excess Proceeds (appearance required)

Summary: Excess proceeds hearings are set for Tuesdays at 3:00 PM and require an appearance.

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

Civil cases

Motions for Summary Judgment are heard by submission only unless otherwise requested by the parties.

Summary: Summary judgment motions are heard by submission unless a party requests a hearing.

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

Civil cases

Tuesdays @ 11:00 Submission Docket (no appearance needed) Motion for New Trial Appointment of Ad Litem's Substitute Service Motion to Transfer Motion for New Trial Strike Pleadings Plea in Abatement Motion for Mediation Motion for Re-Appointment Motion to Consolidate Any Pre-Trial Matters

Summary: The listed motions are set on the Tuesday 11:00 AM submission docket and are ruled on without an appearance.

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

Civil cases

Tuesdays @ 1:00 DWOP (retains will be ruled on without an appearance)

Summary: Motions to retain in DWOP cases are ruled on without an appearance at the Tuesday 1:00 PM DWOP docket.

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

Civil cases

A hearing may be requested on Summary Judgment motions by any party by filing a written request with the Court.

Summary: Any party may request a hearing on a summary judgment motion by filing a written request with the Court.

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

Civil cases

You must file your motion first before setting your hearing.

Summary: The motion must be filed before setting a hearing.

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

Civil cases

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

Summary: Parties should confer before filing any discovery-related motion.

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

Civil cases

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

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

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

Civil cases

With the exception of dispositive motions, motions for voluntary dismissal non-suits, post-verdict motions, and motions involving service of process, you must confer with opposing counsel prior to filing a motion and include a detailed certificate of conference.

Summary: Before filing most motions, counsel must confer with opposing counsel and include a detailed certificate of conference, with exceptions for specified motion types.

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

Civil cases

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

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

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

Civil cases

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

Summary: A late expert-exclusion motion will not be considered without a motion for leave showing exceptionally good cause.

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

Civil cases

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

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

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

Civil cases

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

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

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

Civil cases

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

Summary: Before an emergency hearing, parties must consult with each other, preferably lead attorney to opposing lead attorney.

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

Civil cases

Pursuant to 4.1 herein, any Motions to exclude or challenge expert evidence should be filed and set for hearing on a date in advance of trial.

Summary: Motions to exclude or challenge expert evidence must be filed and set for hearing before trial.

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

Civil cases

Motions for substituted service will be placed on the submission docket; no notice of submission is required.

Summary: Rule 106 motions for substituted service are placed on the submission docket without a notice of submission.

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

Civil cases

In other circumstances, counsel should seek reimbursement of reasonable costs rather than sanctions.

Summary: When no prior court order has been violated, counsel should seek reasonable costs rather than sanctions.

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

Civil cases

These motions are immediately presented to Judge Aston without the necessity of submission or oral hearing.

Summary: Non-suit motions are presented immediately to Judge Aston without submission or an oral hearing.

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

Civil cases

There will be a pretrial conference, generally held the week before the two-week trial docket, for each case set for trial. The Trial Coordinator will contact the parties to confirm the date of the pretrial conference.

Summary: A pretrial conference is generally held the week before the two-week trial docket; the Trial Coordinator confirms the date.

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

Civil cases

The Court does not require mediation in every case. It may, however, order mediation on a case-by-case basis.

Summary: Mediation is not required in every case but may be ordered on a case-by-case basis.