Courtesy copies are required for emergency motion. Details: 1 copy, delivery immediately upon filing, by email. For emergency motions, file via CM/ECF then email a copy to the Case Manager immediately; extension motions are not emergencies.
Judge Drew B. Tipton's rules set a pre-motion procedure for discovery and scheduling dispute. Lead counsel must personally confer on all discovery and scheduling disputes before involving the Court.
Judge Drew B. Tipton's rule states these limits: 2 pages. Opposing party must submit responsive pre-motion letter of up to 2 pages.
Judge Drew B. Tipton's rules include page or word limits for covered filings. Reply letters to pre-motion letters regarding discovery and scheduling disputes are prohibited.
Judge Drew B. Tipton's formatting rule includes binding tabbed 3-ring, organize exhibits and attachments by tab at right margin, use smallest comfortable binders, maximum 4 inches, and mark with file-stamped cm/ecf docket number unless urgent. Hard copy courtesy copies must be tabbed at the right margin, in binders no larger than 4 inches, marked with CM/ECF docket number unless urgent.
The rule identifies required filing content or certificates. Counsel and pro se parties must file a certificate of interested parties with the Clerk at least 15 days before the Scheduling Conference, listing all financially interested entities and underlining corporation names.
The rule identifies required filing content or certificates. Joint Discovery/Case Management Plan must state time and location of Rule 26(f) meeting.
Parties may contact Judge Drew B. Tipton's chambers by email only as allowed by the rule. The rule lists email Kellie_Papaioannou@txs.uscourts.gov. Pre-motion letters must be sent by email to the Court’s case manager Kellie Papaioannou at Kellie_Papaioannou@txs.uscourts.gov.
A motion to seal is required for covered sealed filings before Judge Drew B. Tipton. Process: file redacted on ecf and file unredacted to clerk. Sealing requires a motion to seal filed on public docket with redacted material; unredacted material filed under seal on ECF with SEALED designation and informative title.
Judge Drew B. Tipton's rules specify what an adjournment or extension request must include. Motions to extend discovery deadlines must be filed sufficiently early to allow opposing counsel to respond before the original deadline.
Counsel and pro se parties must file a certificate of interested parties with the Clerk at least 15 days before the Scheduling Conference, listing all financially interested entities and underlining corporation names.
Amended certificate of interested parties must be filed promptly if new interested parties are identified; unincorporated entity certificates must state all members' citizenship.
Lead counsel must personally confer on all discovery and scheduling disputes before involving the Court.
Pre-motion letter (max 2 pages) required to seek permission to file discovery/scheduling dispute motions, must include specified content and copy all parties.
Opposing party must submit responsive pre-motion letter of up to 2 pages.
Reply letters to pre-motion letters regarding discovery and scheduling disputes are prohibited.
Pre-motion letters regarding discovery and scheduling disputes must be emailed to the Court’s case manager.
Court may resolve discovery/scheduling disputes via letters or telephonic/video conference, and set briefing schedule if motion is allowed.
Motions to extend discovery deadlines must be filed sufficiently early to allow opposing counsel to respond before the original deadline.
Joint Discovery/Case Management Plan must state time and location of Rule 26(f) meeting.
Joint Discovery/Case Management Plan must identify counsel who attended Rule 26(f) meeting for each party.
Joint Discovery/Case Management Plan must specify federal jurisdiction basis and identify disagreeing parties with reasons.
Joint Discovery/Case Management Plan must identify diversity jurisdiction disputes about amount in controversy.
Joint Discovery/Case Management Plan must state citizenship of all members/partners for unincorporated entity parties.
Unincorporated entity parties must attach affidavit or declaration of all members' citizenship to Joint Discovery/Case Management Plan.
Joint Discovery/Case Management Plan must include general case description and elements of all claims, defenses, and counterclaims.
Joint Discovery/Case Management Plan must list all related state and federal cases with court, case number, and relationship details.
Joint Discovery/Case Management Plan must describe class/collective action issues, proposed class definition, and opposition basis.
Joint Discovery/Case Management Plan must list unserved parties and provide firm service date.
Joint Discovery/Case Management Plan must list parties to be added, explain reason, and provide date for addition.
Joint Discovery/Case Management Plan must list and explain anticipated interventions.
Joint Discovery/Case Management Plan must include certification that all parties filed required Disclosure of Interested Persons.
Joint Discovery/Case Management Plan must state initial disclosure completion status and provide completion dates if incomplete.
Joint Discovery/Case Management Plan must state whether phased discovery was considered.
Joint Discovery/Case Management Plan must specify all completed or ongoing discovery.
Joint Discovery/Case Management Plan must describe requested changes to FRCP discovery limitations.
Joint Discovery/Case Management Plan must describe discoverable information preservation issues.
Joint Discovery/Case Management Plan must specify all existing discovery disputes.
Joint Discovery/Case Management Plan must state whether protective order will be requested and describe confidentiality issues.
Joint Discovery/Case Management Plan must state whether e-discovery order will be requested and describe ESI issues.