Southern District of Texas Filing Timing and Cure Windows

Pro Hac Vice motions and Notices of Appearance must be filed at least 7 days before counsel's planned appearance.

Source text: Motions to Appear Pro Hac Vice and Notices of Appearance must be on file a week before counsel plans to appear.

Joint discovery/case management plans must be filed 10 days before the scheduling conference, using the required form, after a Rule 26(f) conference.

Source text: counsel and/or the parties must confer (in person or by telephone) as required by Federal Rule of Civil Procedure 26(f) and must prepare and file a joint discovery/case management plan containing the information required by Rule 26(f) no later than ten (10) days before the scheduling conference. The joint discovery/case management plan must be completed using the form available at http://www.txs.uscourts.gov/sites/txs/files/ahb_jdcmp.pdf.

Responses to motions must be filed within 21 days per Local Rule 7.4, unless the Court orders an expedited response.

Source text: Pursuant to Local Rule 7.4, responses must be filed within twenty-one (21) days unless the Court orders an expedited response;

Reply briefs must be filed within 7 days of the response to the motion.

Source text: A reply must be filed within seven (7) days of the response.

Service must be perfected within 120 days of complaint filing, or defendant may be dismissed per Rule 4(m).

Source text: Any defendant upon whom service has not been perfected within 120 days of the filing of the complaint may be dismissed for want of prosecution in accordance with FED. R. CIV. P. 4(m).

Jury trial parties must file pretrial filings 14 days before docket call/pretrial conference, plus Joint Pretrial Order in civil cases.

Source text: No later than fourteen (14) days before the docket call or pretrial conference, each party must file (1) an Exhibit List, (2) a Witness List, (3) Deposition Designations, (4) Objections to Exhibits, Witnesses, and Deposition Designations, (5) Proposed Jury Instructions, and (6) Motions in Limine. In civil cases, the parties must also file a Joint Pretrial Order.

Bench trial parties must file Proposed Findings of Fact and Conclusions of Law 14 days before docket call with required citations.

Source text: No later than fourteen (14) days before the docket call, each party must file (1) Proposed Findings of Facts, citing deposition testimony, expected witness testimony, exhibits, and other evidence, and (2) Proposed Conclusions of Law, citing legal authority to support each conclusion the party seeks at trial.

Parties must file supplemental proposed findings/conclusions post-trial as directed by court, citing trial evidence.

Source text: Following trial, and at a time directed by the Court, each party must file Supplemental Proposed Findings of Fact and Proposed Conclusions of Law, with citations to specific trial testimony and admitted evidence.

Written notice of request for daily transcript or real time reporting due 6/3/06 (same day as Joint Pretrial Order).

Source text: Written notice due for request for daily transcript or real time reporting of trial proceedings.

Motions for extension of discovery must be filed early enough to allow opposing counsel to respond before the discovery deadline.

Source text: Motions for extension of discovery must be filed sufficiently in advance of the discovery deadline that opposing counsel may respond prior to the deadline.

Replies to responses must be filed within 7 calendar days of the response filing date.

Source text: (A) The Reply should be filed within seven (7) days of the date the Response was filed.

Joint Pretrial Orders must be filed one week prior to trial.

Source text: Counsel for the plaintiff is responsible for ensuring that the Joint Pretrial Order is filed on time one week prior to trial.

Agreed civil jury instructions must be submitted via email (Word format) and hard copy at least 1 business day before trial.

Source text: One set of proposed jury instructions that have been agreed to by counsel should be submitted to the Court electronically (via email in a Word format) and in hard copy at least one business day before the first day of trial.

Written objections to exhibits in final pretrial order must be filed 3 business days before trial to prevent automatic admission.

Source text: The Court will admit all exhibits listed in the final pretrial order into evidence unless opposing counsel files written objections supported by authority at least three (3) business days before trial. See Local Rule 46 and CrLR55.2B.

Objections to designated deposition portions must be filed at least 3 business days before trial.

Source text: Objections to those portions (citing pages and lines) with supporting authority must be filed at least three (3) business days before trial.

Submitting a completed scheduling order one week before the scheduled initial conference cancels the conference.

Source text: If you return the completed scheduling order one week prior to your scheduled hearing, the conference will be cancelled.

Leave of court is required to add inequitable conduct allegations to pleadings after the invalidity contentions deadline.

Source text: Add any inequitable conduct allegations to pleadings. Before this date, it is not necessary to file a motion for leave to add inequitable conduct allegations to pleadings. Thereafter, it is necessary to obtain leave of court to add inequitable conduct allegations to pleadings.

New parties must be joined by the date specified in paragraph 1 of the scheduling order.

Source text: NEW PARTIES shall be joined by:

All discovery must be completed by the date specified in paragraph 4 of the scheduling order.

Source text: DISCOVERY must be completed by:

Written discovery requests are untimely if filed too close to the discovery completion deadline to allow a timely response under the FRCP.

Source text: Written discovery requests are not timely if they are filed so close to this deadline that the recipient would not be required under the Federal Rules of Civil Procedure to respond until after the deadline.

Dispositive and non-dispositive motions (except motions in limine) must be filed 90 days prior to the trial date.

Source text: DISPOSITIVE AND NON-DISPOSITIVE MOTIONS (except motions in limine) will be filed by: (Due 90 Days Prior to Trial Date)

Joint pretrial orders must be filed on Monday one week prior to the trial date.

Source text: JOINT PRETRIAL ORDER and MOTIONS IN LIMINE (The Court will fill in this date) (Due Monday one week before trial)

Leave of court is required to add or amend infringement contentions after the initial disclosure deadline.

Source text: After this date, it is necessary to obtain leave of court to add and/or amend infringement contentions, pursuant to Patent Rule (P.R.) 3-7.

Leave of court is required to join additional parties after the initial infringement contention disclosure deadline.

Source text: Thereafter, it is necessary to obtain leave of court to join additional parties.

Leave of court is required to add new patents or claims after the initial infringement contention disclosure deadline.

Source text: Thereafter, it is necessary to obtain leave of court to add patents or claims.

Leave of court is required to add or amend invalidity contentions after the service deadline.

Source text: Thereafter, it is necessary to obtain leave of Court to add and/or amend invalidity contentions, pursuant to P.R.. 3-7.

Video and Deposition Designations due 6/3/06; must identify line and page numbers of video depositions offered.

Source text: Video and Deposition Designations due. 6/3/06 Each party who proposes to offer a depositions by video must file a disclosure identifying the line and page numbers to be offered.

Responses requesting cross designation due 1 week (7 calendar days) after Video/Deposition Designations are filed.

Source text: All other parties will have 1 week to file a response requesting cross designation line and page numbers to be included.

Motions in Limine due 6/3/06 (same day as Joint Pretrial Order).

Source text: Motions in Limine due. 6/3/06

Objections to opposing parties’ witnesses, exhibits, deposition testimony due 6/10/06 (1 week after Joint Pretrial Order).

Source text: Objections to opponents’ proposed witnesses, proposed exhibits, designated deposition testimony, and any other matters due. 6/10/06

Filings with 50 or more pages (including attachments) must submit a hard copy to the District Clerk’s Office within 7 days of electronic filing.

Source text: If a filing, including attachments, contains 50 pages or more, the party must submit the filing electronically and submit a hard copy to the District Clerk’s Office. The hard-copy filing must be submitted to the District Clerk’s Office within seven days after the electronic

Opposed motion responses must be filed within 21 calendar days of the motion's filing date.

Source text: Be filed within 21 days from the date the motion was filed with the District Clerk’s Office.

Failure to respond to an opposed motion constitutes no opposition; court rules on motions when ripe regardless of response.

Source text: Failure to respond to an opposed motion will be deemed as a representation of no opposition. The Court will rule on any motion once it becomes ripe no matter if a response has been filed.

Reply briefs must be filed no more than 10 calendar days after the response is filed.

Source text: If the movant elects to reply, it must be filed no more than 10 days after the response was filed with the District Clerk’s Office.

Surreplies must be filed no more than 10 calendar days after the reply is filed.

Source text: Surreplies must be filed no more than 10 days after the reply was filed with the District Clerk’s Office.

Objections to deposition excerpts must be filed within 15 days after the JPO deadline.

Source text: Objections to deposition excerpts must be filed within 15 days after the JPO deadline.

Joint Pretrial Order must be filed by the deadline set in the Scheduling Order.

Source text: Counsel must ensure that the JPO is filed by the date listed on the Scheduling Order.

If the case is continued or abated, a supplemental JPO must be filed at least 60 days before the revised Final Pretrial Conference.

Source text: If a JPO is filed, but the case is later continued or abated, a supplemental JPO must be filed at least 60 days before the revised Final Pretrial Conference.

Objections to exhibits/witnesses must be filed 15 days after JPO deadline; responses 30 days after objections.

Source text: Objections to any exhibits or witnesses must be filed 15 days after the JPO deadline; objections must include copies of the disputed exhibit and legal authority. Responses to objections must be filed 30 days after the objections are filed.

If there is no appeal, the offering party must remove exhibits within 30 days after disposition of the case.

Source text: (1) If there is no appeal, exhibits must be removed by the offering party within 30 days after disposition of the case.

When there is an appeal, the offering party must remove exhibits within 10 days after written notice from the District Clerk.

Source text: (2) When there is an appeal, exhibits returned to the Court by the Court of Appeals must be removed by the offering party within 10 days after written notice from the District Clerk.

Proposed voir dire questions must be filed with the Joint Pretrial Order (JPO).

Source text: Proposed voir dire questions must be filed with the JPO.

Notices of Settlement must include a separate Agreed Judgment or Stipulation of Dismissal within 30 days of the notice.

Source text: must include a separate Agreed Judgment or Stipulation of Dismissal within 30 days of the Notice of Settlement.

Counsel must file a list of financially interested entities within 15 days of receiving the order and amend promptly when changes occur.

Source text: Within 15 days of receiving this order, counsel must file a list of all entities that are financially interested, including parent, subsidiary, and affiliated corporations as well as all known attorneys of record. When a group description is effective disclosure, an individual listing is unnecessary. Underline the names of corporations with publicly traded securities. Counsel must promptly amend the list when parties are added, or additional interested parties are identified.

Joint case management plan must be filed at least 14 days before the initial pretrial conference.

Source text: 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 at least 5 days before initial pretrial conference.

Source text: 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. expert designation dates and discovery deadlines, as well as dates for exchanging of initial disclosures if they have not already been completed.

Plaintiff's expert designations and reports due 180 days before discovery deadline.

Source text: The plaintiff’s expert designation and expert report deadline: 180 days before discovery deadline. See FRCP 26(a)(2)(D); Local Rule 9(A)(4).

New parties must be joined within 180 days of complaint filing or notice of removal.

Source text: New party joinder deadline: 180 days from complaint or, in a removed case, notice of removal.

Defendant's expert designations and reports due 120 days before discovery deadline.

Source text: The defendant’s expert designation and expert report deadline: 120 days before discovery deadline. See FRCP 26(a)(2)(D); Local Rule 9(A)(5).

All discovery must be completed 90 days before Joint Pretrial Order deadline.

Source text: Discovery completion deadline: 90 days before JPO deadline

Mediation and status reports due 30 days after JPO filing.

Source text: The parties’ mediation and status report deadline: 30 days after JPO deadline

Non-dispositive motions must be filed 30 days after discovery deadline.

Source text: Non-dispositive motions deadline: 30 days after discovery deadline

Responses to dispositive and non-dispositive motions due 21 days after filing.

Source text: Responses to dispositive and non-dispositive motions are due 21 days after the motions are filed. See Local Rule 6(C)(2)

Daubert and expert exclusion motions due 60 days before JPO deadline.

Source text: Daubert motions/motions to exclude expert deadline: 60 days before JPO

Joint Pretrial Order with witness and exhibit lists due 60 days before Final Pretrial Conference.

Source text: Joint pretrial order (“JPO”) (including witness/exhibit lists) deadline: 60 days before FPC

Objections to exhibit or witness lists due 15 days after JPO filing.

Source text: Objections to exhibit or witness lists deadline: 15 days after JPO

Responses to exhibit/witness list objections due 30 days after JPO filing.

Source text: Responses to objections to exhibit and witness lists deadline: 30 days after JPO

Motions in limine due 15 days after JPO filing.

Source text: Motions in limine deadline: 15 days after JPO

Responses to motions in limine due 30 days after JPO filing.

Source text: Responses to motions in limine deadline: 30 days after JPO

Responses to dispositive and non-dispositive motions must be filed within 21 days of the motion's filing.

Source text: Responses to dispositive and non-dispositive motions are due 21 days after the motions are filed. See Local Rule 6(C)(2)

Court will rule on default judgment motion no sooner than 21 days after filing if no hearing is needed.

Source text: If no hearing is necessary, the Court will rule on the Motion for Default Judgment no sooner than twenty-one (21) days after the filing of the motion.