Judge Christine A. Nowak
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Page & Word Limits1 rule
The joint trial summary should be limited to one page.
This summary is intended to be an aid for the Court and should be limited to one page.
Joint Trial Summary
1 pages
Document Format Requirements2 rules
Each party must provide proposed jury charges in hard copy and by emailing an editable Word version to the court coordinator.
Proposed jury charges (instructions, definitions, and questions) in hard copy and emailed in editable Word format to the court coordinator.
DOCX
A proposed property division must be provided to the court at the beginning of trial in both hard-copy and electronic formats.
A Proposed Property Division should be provided to the Court at the beginning of trial, in both hard copy and electronic format, which lists all assets and liabilities, whether community, separate, or mixed character.
Document Filing Requirements11 rules
A testifying expert disclosure must contain all information required by the rules, and an improperly disclosed expert may not testify.
Any expert not properly disclosed will not be permitted to testify. A testifying expert disclosure must include all information required by the rules.
Document Type
Testifying Expert Disclosure
The sworn inventory must describe and value all owned or claimed property and list all debts, including each creditor and amount owed.
Sworn Inventory: For Divorce cases, each party shall serve the other party within 30 days of this Order with a sworn inventory setting forth a description and value of all property (real or personal; community, separate, and mixed) owned or claimed by the parties and a list of all debts (stating the creditor and amount) owed by the parties
Document Type
Sworn Inventory
Every discovery motion or request for a discovery hearing must include a certificate of conference.
**Per Rule 191.2, all discovery motions or requests for hearing relating to discovery must contain a certificate of conference
Document Type
Discovery Motion Or Hearing Request
All discovery motions and requests for a discovery hearing must include a certificate of conference.
**Per Rule 191.2, all discovery motions or requests for hearing relating to discovery must Date: contain a certificate of conference**
Document Type
Discovery Motion
A testifying expert disclosure must include all information required by the applicable rules.
A testifying expert disclosure must include all information required by the rules.
Document Type
Testifying Expert Disclosure
Each party must produce a joint trial summary for any cause of action outside the Family Code, including the elements of each cause of action and defense and, when appropriate, the legal standard for measuring damages.
A JOINT trial summary for any cause of action outside the Family Code, including each element of each cause of action and defense and, if appropriate, a precise legal standard for measure of damages.
Document Type
Joint Trial Summary
Each party must produce all exhibits to the court reporter and pre-mark them for identification.
All exhibits produced to court reporter and pre-marked for identification (for the purpose of stipulating to the authenticity and admissibility of exhibits).
Document Type
Trial Exhibits
Each party must produce completed witness lists and exhibit lists at the pretrial conference.
Completed witness lists and exhibit lists.
Document Type
Witness And Exhibit Lists
Each party must designate deposition testimony intended to be offered at trial.
Designation of any deposition testimony to be offered.
Document Type
Deposition Testimony Designation
If opposing counsel or a party will not sign the order or agree to a trial date, a letter describing the filer’s efforts must be filed.
If you cannot get an opposing counsel or party to sign this order or agree to a trial date, please file a letter describing your efforts and submit your proposed scheduling order to the court
Document Type
Letter
A proposed property division must list all assets and liabilities and identify whether each is community, separate, or mixed property.
A Proposed Property Division should be provided to the Court at the beginning of trial, in both hard copy and electronic format, which lists all assets and liabilities, whether community, separate, or mixed character.
Document Type
Proposed Property Division
Filing & Service rules
Filing Timing and Cure Windows
Summary-judgment motions must be filed, set for hearing, and heard at least 30 days before trial or they are waived, and the deadline cannot be moved without leave of court.
All motions for summary judgment Trial Setting motions must be filed, set for hearing, and heard at least thirty (30) days before trial or they Date: are waived, absent leave of court. **This deadline cannot be moved without leave of court**
Page 3 | Motions for Summary Judgment
An objection or motion to exclude or limit expert testimony must be filed at least 30 days before trial and heard by the pre-trial conference or it is waived, and the deadline cannot be moved without leave of court.
Any objection or motion to Trial Setting exclude or limit expert testimony must be filed at least thirty (30) days before trial and Date: heard at or before the pre-trial conference or it is waived. **This deadline cannot be moved without leave of court**
Page 3 | Motions to Exclude Expert Testimony
All pretrial motions must be filed at least 10 days before the formal pretrial conference and will be heard at that conference.
All pre-trial motions (motions in limine, etc.) shall be filed at least 10 days before the formal pre-trial conference and will be heard at the formal pre-trial conference.
Page 1 | FORMAL PRE-TRIAL CONFERENCE
Summary-judgment motions must be filed, set for hearing, and heard at least 30 days before trial or they are waived absent court permission.
All motions for summary judgment Initial Trial Setting motions must be filed, set for hearing, and heard at least thirty (30) days before trial or they are waived, absent leave of court.
Page 2 | MOTIONS FOR SUMMARY JUDGMENT
A motion to compel discovery responses must be filed within 10 days after discovery closes or the complaint is waived, except for exclusion under Rule 193.6.
Any motion to compel responses to discovery days after must be filed no later than 10 (ten) days after the close of the discovery period or such discovery period complaint is waived, except for the sanction of exclusion under Rule 193.6.
Page 2 | MOTIONS TO COMPEL DISCOVERY
Objections or motions to exclude or limit expert testimony must be filed at least 30 days before trial and heard at or before the pretrial conference or be waived.
Any objection or motion to Initial Trial Setting exclude or limit expert testimony must be filed at least thirty (30) days before trial and heard at or before the pre-trial conference or it is waived.
Page 2 | MOTIONS TO EXCLUDE EXPERT TESTIMONY
Service and Proof of Service Rules
In divorce cases, each party must serve a sworn inventory on the other party within 30 days after the order.
Sworn Inventory: For Divorce cases, each party shall serve the other party within 30 days of this Order with a sworn inventory setting forth a description and value of all property (real or personal; community, separate, and mixed) owned or claimed by the parties and a list of all debts (stating the creditor and amount) owed by the parties
Page 2 | Sworn Inventory
Amended pleadings asserting new claims or defenses must be filed with the court and served on all other parties by the stated deadline.
Parties shall file with the Court and serve all other parties with any amended pleadings asserting new causes of action/claims for affirmative relief or defenses by this date.
Page 1 | AMENDED PLEADINGS
Adjournment & Extension Requirements
A continuance or reset of the initial trial setting will not alter established deadlines unless the parties agree under Rule 11 or the court orders a change after a motion showing good cause.
Reset or continuance of the Initial Trial Setting will not alter any deadline established by this Order or established by the Texas Rules of Civil Procedure, unless specifically provided by Rule 11 of the parties or Court order after motion showing good cause.
Page 1 | Trial Setting
The court ordinarily will not continue an agreed trial setting except in an emergency or when other good cause is shown.
It is the policy of this Court not to grant a continuance of any trial setting when such date has been agreed to by the parties or attorneys, except in an emergency or for other good cause shown.
Page 2 | Bench Trial