Southern District of Texas Filing Bundling Requirements

CRITICAL

E-file Schedule C-1 following Schedule C.

E-file Schedule C-1 following Schedule C.

CRITICAL

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.

CRITICALCivil cases

Submitted with Motion (Form O-1)

Submitted with Motion (Form O-1)

CRITICALCivil cases

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.

CRITICAL

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.

CRITICALCivil cases

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.

CRITICAL

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.

CRITICAL

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.

CRITICAL

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.

CRITICAL

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.

CRITICAL

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.

CRITICAL

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.

CRITICALCivil cases

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.

CRITICALCivil cases

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.

CRITICALCivil cases

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.

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.

CRITICAL

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.

CRITICALCivil cases

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.

CRITICALCivil cases

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.

CRITICALCivil cases

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.

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.

CRITICAL

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.

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.

CRITICAL

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

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

CRITICALCivil cases

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.

CRITICAL

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.

CRITICALCivil cases

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.

CRITICAL

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.

CRITICAL

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.

CRITICAL

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

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

CRITICAL

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.

CRITICALCivil cases

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.

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.

CRITICALCivil cases

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

CRITICALCivil cases

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).

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).

CRITICALCivil cases

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.

CRITICAL

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.

CRITICAL

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.

CRITICALCivil cases

All motions in limine must be submitted with the Pretrial Order.

All MOTIONS IN LIMINE shall be submitted with Pretrial Order.

CRITICAL

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.

CRITICAL

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

CRITICAL

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.

CRITICAL

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

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

CRITICALCivil cases

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.

CRITICALCivil cases

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.

CRITICALCivil cases

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

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

CRITICALCivil cases

Counsel may not combine two different and unrelated pleadings (motions, responses, replies, or exhibits) 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.

CRITICALCivil cases

Required pretrial order attachments must be filed as separate documents rather than bundled with the joint pretrial order.

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

CRITICALCivil cases

All motions should incorporate supporting briefs or authority and pertinent exhibits. Motions are not to exceed twenty pages. Briefs must be filed together with or incorporated within a motion, response, or reply.

All motions should incorporate supporting briefs or authority and pertinent exhibits. Motions are not to exceed twenty pages. Briefs must be filed together with or incorporated within a motion, response, or reply.

CRITICAL

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.

WARNING

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

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

WARNING

A party should not file a motion and separate “Memorandum of Law.” The motion should include the party’s argument supporting the relief sought.

A party should not file a motion and separate “Memorandum of Law.” The motion should include the party’s argument supporting the relief sought.

WARNING

Motions to seal and all exhibits to motions to seal must 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.

WARNING

Parties should not file a joint pretrial order; each party submits its own pretrial filings instead.

The parties should not file a joint pretrial order.

WARNINGCriminal cases

Counsel must not combine different, unrelated pleadings in one electronically filed document.

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

WARNINGCriminal cases

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

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

INFO

Joint Exhibit List is encouraged where possible.

When possible, a Joint Exhibit List is preferred.

INFOCivil cases

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.

INFOCivil cases

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.

CRITICAL

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.

CRITICALCriminal cases

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.