Southern District of Texas Filing Bundling Requirements

Schedule C-1 must be electronically filed immediately after Schedule C.

E-file Schedule C-1 following Schedule C.

B 122 Form must be e-filed as a separate CM/ECF event.

The B 122 Form, as applicable, need to be e-filed as a separate CM/ECF event.

Separate motions must be filed for additional relief in motions for payments outside ordinary course or implicating §503(c).

26. a. Motions sought for payments outside of the ordinary course of business or that implicates § 503(c), a separate motion seeking that additional relief should be filed.

Form O-1 (proposed order) must be submitted with the motion.

Submitted with Motion (Form O-1)

Plan summary must be filed as a separate document and is prohibited from being attached to petitions, schedules, or other documents.

Plan summary must be filed as separate document. It must NOT be filed as an attachment to the petition, schedules or other documents.

Parties represented by counsel must file Form JS44c with all original pleadings.

Parties represented by counsel must file a civil action cover sheet (Form JS44c) with all original pleadings.

Motions must be filed as separate CM/ECF documents, not as exhibits or attachments to other documents.

A motion must be filed as its own, separate document on CM/ECF and not as an exhibit or attachment to any other document.

Exhibits must be uploaded as a single attachment on CM/ECF; cover sheets required for each exhibit, table of contents for numerous attachments.

Supply affidavits, deposition testimony excerpts, and supporting documents as exhibits to any filing. Provide a cover sheet to identify and separate each exhibit. Prepare and submit a table of contents when attachments are numerous. Separately upload these exhibits together as a single attachment during filing on the CM/ECF system.

Non-Westlaw/Lexis authorities must be appended as single attachment on CM/ECF; cover sheets and table of contents required.

Supply all cases or other authority not readily available through Westlaw or Lexis-Nexis as an appendix to any filing. Provide a cover sheet to identify and separate each authority. Prepare and submit a table of contents. Separately upload any appendix as a single attachment during filing on the CM/ECF system.

When filing Joint Pretrial Order on CM/ECF, attach all pretrial filings listed in Section 21.

b. Same-day filings. When filing the Joint Pretrial Order on the CM/ECF system, attach the pretrial filings set out in Section 21.

Joint trial notebook required, materials paired in order listed; JPO first item in civil cases.

Confer, prepare, and provide a joint trial notebook. Include each party’s materials paired together in the order listed above. In civil cases, include the Joint Pretrial Order as the first item.

Joint filing of parties’ exchanges for deposition designations is required 24 hours before intended use.

As to each intended deposition designation, the designator must make a joint filing comprehending the parties’ exchanges twenty-four hours in advance of intended use.

Joint proposed findings of fact and conclusions of law must be submitted as a single document with an agreed outline.

Submit the proposed findings and conclusions as a single document according to an agreed outline that the parties believe makes the most sense.

Memoranda exceeding 15 pages must be bundled with a concise summary of no more than 3 pages.

Any memorandum that is more than 15 pages must be accompanied by a concise summary, no longer than 3 pages, narrowing the points in the brief.

Exhibits referenced in briefs, and unpublished/non-Texas state cases not on Westlaw/Lexis must be attached to the brief or pleading.

All exhibits (contract, leases, affidavits, etc.) referred to in briefs must be attached to the brief. Copies of all unpublished cases (not available on West law or Lexis) and all state cases (not available on West law or Lexis) other than Texas cases cited shall also be attached to the pleading.

Pleadings submitted during trial must be presented in duplicate (original for filing, copy for court) to the Case Manager.

Pleadings submitted by counsel during the course of a trial should be presented in duplicate (original for filing; copy for the Court) to the Case Manager.

Section 19 pretrial filings must be filed as exhibits with the Joint Pretrial Order on CM/ECF.

When filing the Joint Pretrial Order on the CM/ECF system, file the pretrial filings set out in Section 19 as exhibits.

Joint Trial Notebook must be submitted jointly; if counsel cannot cooperate, each side submits its own notebook and exhibits.

The Trial Notebook should be submitted jointly, and must contain the Joint Pretrial Order as well as each side’s Exhibit Lists, Witness Lists, Designations, Objections, Motions in Limine, Jury Charges (where applicable), Memoranda of Law, and Proposed Findings of Fact and Conclusions of Law (where applicable). If counsel are wholly unable to cooperate, then each side is responsible for ensuring that its own Trial Notebook and exhibit binders are submitted.

All motions in limine must be filed with the pretrial order.

All Motions in Limine must be filed along with the Pretrial Order.

Motions to seal and their exhibits should be filed as a single combined document.

Motions to seal and all exhibits to motions to seal should be filed as a single, combined document.

Joint pretrial orders are prohibited; parties must file separate pretrial filings 24 hours before docket call.

The parties should not file a joint pretrial order. Instead, at least 24 hours before docket call, each party must file separate pretrial filings containing the following document: exhibit list, witness list, proposed voir dire questions, proposed jury instructions, motions in limine, and deposition designations and objections.

Required attachments must be filed as separate documents, not bundled together.

14. Attachments. Each party must file as a separate document (captioned, signed by counsel, and with service certified) these required attachments in duplicate.

Required attachments must be filed as separate documents, not bundled with the Joint Pretrial Order.

Each party must file as a separate document (captioned, signed by counsel, and with service certified) these required attachments in duplicate.

Briefs are required to be filed together with or incorporated within a motion, response, or reply.

Briefs must be filed together with or incorporated within a motion, response, or reply.

Counsel must provide the Court with a tabbed and indexed notebook copy of their exhibits prior to the Final Pretrial Conference.

Counsel for each party is required to provide the Court with a copy of that party's exhibits in a properly tabbed and indexed notebook.

Prior to Final Pretrial Conference, offering party must provide copy of exhibits in properly tabbed and indexed notebook.

Prior to the Final Pretrial Conference, the offering party will mark each exhibit to be offered with the party's identity, case number, and exhibit copy of that party's exhibits in a properly tabbed and indexed notebook.

Opening Brief and exhibits must be bound in binders for court copies.

The moving party is to provide the Court with 2 copies of the binders containing their Opening Brief and exhibits.

Required pretrial attachments must be filed as separate documents, prohibiting bundling.

Each party must file as a separate document (captioned, signed by counsel, and with service certified) these required attachments in duplicate.

Joint Pretrial Orders filed on CM/ECF must have Section 19 pretrial filings attached as exhibits.

When filing the Joint Pretrial Order on the CM/ECF system, attach the pretrial filings set out in Section 19 as exhibits.

Each party must file all required pretrial filings (exhibit list, witness list, etc.) on the date the Joint Pretrial Order is filed, unless the Court orders otherwise.

Unless otherwise set by Court order, on the date the Joint Pretrial Order is filed each party must file: • An exhibit list (Section 20); • A witness list (Section 21); • Designation of deposition excerpts (Section 22); • Motions in limine (Section 23); • Proposed topics and questions for voir dire (Section 24); • In jury trials, a proposed joint jury charge (Section 25); and • In bench trials, proposed findings of fact and conclusions of law • A trial memorandum of law identifying and addressing the legal propositions that are necessary to the disposition and relief sought in the case, with indication of those which are not in dispute.

Motions in limine must be filed separately; bundling of multiple motions in limine is prohibited.

File separate motions in limine with a matching proposed order on the same date the Joint Pretrial Order is filed.

Post-trial joint proposed findings of fact and conclusions of law must be submitted as a single document.

Following trial and at the time directed by the Court, the parties shall file a joint proposed findings of fact and conclusions of law. Submit the proposed findings and conclusions as one document and in the order the parties believe makes the most sense.

Notices of Settlement must include a separate Agreed Judgment or Stipulation of Dismissal.

Notices of Settlement must be received in writing and must include a separate Agreed Judgment or Stipulation of Dismissal within 30 days of the Notice of Settlement.

Joint case management plan must be filed jointly by all parties.

At least 14 days before the initial pretrial conference, counsel must file a joint case management plan listing the identities and purposes of witnesses, sources, and types of documents, and other requirements for a prompt and inexpensive preparation of this case for disposition by motion or trial. See Fed R. Civ. P. Rule 26(f).

Joint proposed scheduling order must be filed jointly by all parties.

At least 5 days before the initial pretrial conference, counsel must file a joint proposed scheduling order using the Court’s template and the certificate regarding generative artificial intelligence.

Required attachments for jury and non-jury trials must be filed as separate documents, not bundled together.

14. Attachments. Each party must file as a separate document (captioned, signed by counsel, and with service certified) the following required attachments in duplicate: A. For a Jury Trial: (1) Proposed questions for the voir dire examination. (2) Proposed jury charge, including instructions, definitions, and special interrogatories, with authority. B. For a Non-Jury Trial: (1) Proposed findings of fact and conclusions of law. (2) Conclusions of law with authority

Only one joint Plan and one joint Proposed Scheduling Order may be filed.

The parties are to file with the Court only one Plan and one Proposed Scheduling Order.

Joint Pretrial Orders filed on CM/ECF must include attached pretrial filings specified in Section 19.

When filing the Joint Pretrial Order on the CM/ECF system, attach the pretrial filings set out in Section 19.

Requests for expedited consideration must be filed separately from the motion.

All requests for expedited consideration of motions shall be filed separately from the motion.

Parties must jointly submit two sets of specified trial materials 4 days before trial, printed double-sided, in 4-inch or less binders with index and tabs.

At least four days before the start of trial, the parties must jointly submit two sets of each of the following, printed double-sided, placed in binders of 4-inches or less, and complete with an index and corresponding tabs: • the joint pretrial order; • the parties’ exhibit lists, witness lists, deposition designations, and the joint proposed jury charge and verdict form or proposed findings of fact or conclusions of law, whichever is applicable; and

All motions in limine must be filed with the Joint Pretrial Order.

Note that all motions in limine must filed along with the Joint Pretrial Order.

Prohibited from separating motions, briefs, attachments, or exhibits into separate filings to avoid courtesy copy requirements.

Counsel should NOT attempt to avoid this requirement by unnecessarily separating a motion, brief, and attachments or exhibits into separate submissions.

Prohibited from combining unrelated pleadings into a single electronically filed document.

Counsel shall not combine two different and unrelated pleadings (motions, responses, replies, or exhibits) into the same electronically filed document.

Briefs must be filed together with or incorporated into a motion, response, or reply.

Briefs must be filed together with or incorporated within a motion, response, or reply.

Proposed voir dire questions must be bundled with the Joint Pretrial Order.

Proposed voir dire questions must be submitted as part of the Joint Pretrial Order.

Separate memoranda of law are prohibited; motions must include legal argument and authorities.

Generally, a motion should contain the legal argument and authorities and separate memoranda should not be filed.

Joint Exhibit List is encouraged where possible.

When possible, a Joint Exhibit List is preferred.

Parties are encouraged to file all proposed highlighted redactions as a single document.

Regardless of how many documents the parties seek to redact, the parties should endeavor to file the proposed highlighted redactions as a single document for the court’s convenience.

Discovery materials referred to in briefs should be separately filed in appendices.

Copies of supporting affidavits, deposition testimony excerpts, and other discovery materials referred to in the briefs should be separately filed in one or more appendices.