Judge Jill Renfro Willis
Individual Rules, Standing Orders & Policies
Adjournments
- A continuance or trial reset does not alter existing deadlines unless the parties agree under Rule 11 or the court orders a change after a motion showing good cause.
- A continuance or reset of the initial trial setting does not change existing deadlines unless the parties agree by Rule 11 or the court orders otherwise after a good-cause motion.
Request must include
Document Format Requirements3 rules
For a jury case, proposed jury charges must be provided to the Court Coordinator in hard copy and by email in editable Word format.
For a jury case, proposed jury charges (instructions, definitions, and questions) in hard copy and emailed in editable Word format to the Court Coordinator.
DOCX
In jury cases, proposed jury charges must be provided in hard copy and emailed to the Court Coordinator in editable Word format.
For a jury case, proposed jury charges (instructions, definitions, and questions) in hard copy and emailed in editable Word format to the Court Coordinator.
DOCX
The court prefers descriptive pre-marking of exhibits, such as H-1 for husband’s exhibits or M-1 for mother’s exhibits.
The Court prefers descriptive markings, for example “H-1” for husband’s exhibits or “M-1” for mother’s exhibits.
Document Filing Requirements7 rules
Every discovery motion or request for a discovery-related hearing must contain 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
Each party must produce completed witness lists and exhibit lists at the pre-trial conference.
b. Completed witness lists and exhibit lists.
Document Type
Pretrial Conference Submission
All exhibits must be pre-marked for identification before the pre-trial conference.
c. All exhibits must be pre-marked for identification (for the purpose of stipulating to the authenticity and admissibility of exhibits).
Document Type
Exhibits
Each party must produce the listed materials at the formal pre-trial conference.
Each party is directed to produce the following at the pre-trial conference:
Document Type
Pretrial Conference Submission
Each party must email proposed jury charges in editable Word format to the Court Coordinator at the pre-trial conference.
a. Proposed jury charges (instructions, definitions, and questions) emailed in editable Word format to the Court Coordinator.
Document Type
Proposed Jury Charges
At the pretrial conference, each party must provide proposed jury charges in jury cases, completed witness and exhibit lists, premarked exhibits, and designations of deposition testimony for direct examination.
Each party is directed to produce the following at the pre-trial conference: 1) For a jury case, proposed jury charges (instructions, definitions, and questions) in hard copy and emailed in editable Word format to the Court Coordinator. 2) Completed witness lists and exhibit lists. 3) All exhibits must be produced to the court reporter pre-marked for identification (for the purpose of stipulating to the authenticity and admissibility of exhibits). 4) Designation of deposition testimony to be offered in direct examination.
Document Type
Pretrial Materials
Every discovery motion or request for a discovery-related hearing must contain 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
Filing & Service rules
Filing Timing and Cure Windows
Dispositive motions must be filed at least 30 days before trial.
All dispositive motions (summary judgment, plea to the before trial jurisdiction, plea in abatement, etc.) must be filed at least thirty (30) days before trial.
Page 1 | DISPOSITIVE MOTIONS
Written objections to Daubert/Dupont expert challenges must be filed at least 10 days before the hearing.
Unless good cause is shown, all Daubert/Dupont expert challenges shall be heard no later than the formal pre-trial, and written objections must be on file at least 10 days before hearing.
Page 1 | FORMAL PRE-TRIAL CONFERENCE
A motion to compel discovery responses must be filed within 14 days after the discovery deadline or the complaint is waived, except for exclusion under Rule 193.6.
Any motion to compel responses to discovery must be filed no later than 14 (fourteen) ______________ days after the discovery deadline or such complaint is waived, except for the sanction of (Date) exclusion under Rule 193.6.
Page 2 | IF THIS IS A LEVEL 3 CASE
Amended pleadings asserting new causes of action or defenses must be filed with the court and served on all other parties by the stated date.
Parties shall file with the Court and serve all other parties with any amended pleadings asserting new causes of action or defenses no later ______________ than this date.
Page 2 | IF THIS IS A LEVEL 3 CASE
Responses to amended pleadings, including affirmative defenses or special exceptions, may be filed within two weeks after the amended-pleadings deadline.
Responses to such Amended Pleadings, including any and all affirmative defenses and/or special exceptions may be filed within two (2) weeks after this deadline.
Page 2 | IF THIS IS A LEVEL 3 CASE
Pretrial disclosures must be made at least 30 days before trial.
Parties are required to comply with Rule 194.4 (pretrial disclosures must be made at least 30 days before trial).
Page 1 | Formal Pre-Trial Conference
All pretrial motions must be filed at least 10 days before the formal pretrial conference and 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
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
Joinder of additional parties must occur no later than five months after commencement of the case, absent leave of court on a good-cause motion.
No later than 5 months after commencement of the case
Page 2 | Joinder of Parties
Summary-judgment motions must be filed, set, and heard at least 30 days before trial or they are waived absent leave of court.
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
An objection or motion to exclude or limit expert testimony must be filed at least 30 days before trial and heard by the pretrial conference, absent leave of court.
Any objection or motion to exclude Initial Trial Setting 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. **This deadline cannot be moved without Date: leave of court**
Page 2 | Motions to Exclude Expert Testimony
Daubert/Dupont expert challenges must be filed at least ten days before the hearing or trial.
All Daubert/Dupont expert challenges must be filed at least ten (10) days before hearing/trial.
Page 1 | Bench Trial Setting
All dispositive motions must be filed at least thirty days before trial.
All dispositive motions (summary judgment, plea to the before trial jurisdiction, plea in abatement, etc.) must be filed at least thirty (30) days before trial.
Page 1 | Dispositive Motions
A motion to compel discovery responses must be filed within fourteen days after the discovery deadline, subject to the stated Rule 193.6 exception.
Any motion to compel responses to discovery must be filed no later than 14 (fourteen) ______________ days after the discovery deadline or such complaint is waived, except for the sanction of (Date) exclusion under Rule 193.6.
Page 1 | Discovery Deadline
Amended pleadings asserting new causes of action 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 or defenses no later (Date) than this date.
Page 1 | Amended Pleadings
Parties seeking affirmative relief have a stated deadline for expert designation.
EXPERT DESIGNATION DEADLINE OF PARTIES SEEKING ______________ AFFIRMATIVE RELIEF.
Page 2 | IF THIS IS A LEVEL 3 CASE
Parties opposing affirmative relief have a stated deadline for expert designation.
EXPERT DESIGNATION DEADLINE OF PARTIES OPPOSING ______________ AFFIRMATIVE RELIEF
Page 2 | IF THIS IS A LEVEL 3 CASE
Responses to amended pleadings, including affirmative defenses and special exceptions, may be filed within two weeks after the amended-pleadings deadline.
Responses to such Amended Pleadings, including any and all affirmative defenses and/or special exceptions may be filed within two (2) weeks after this deadline.
Page 1 | Amended Pleadings
Service and Proof of Service Rules
Amended pleadings asserting new claims, affirmative relief, or defenses must be filed with the court and served on all other parties by the scheduling-order 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
A party joining an additional party must serve the scheduling order on the new party concurrently with the joinder pleading.
The party joining an additional party must serve a copy of this Order on the Date: new party concurrently with the pleading joining the new party.
Page 1 | Joinder of Parties
Parties seeking affirmative relief must serve their expert designations and provide the experts' written reports by the scheduling-order deadline.
Parties Initial Trial Setting seeking affirmative relief shall serve his/her/its designation of experts and provide written reports of such experts.
Page 2 | Expert Designations of Party Seeking Affirmative Relief
Parties opposing affirmative relief must serve their expert designations and provide the experts' written reports by the scheduling-order deadline.
Parties opposing affirmative relief shall serve his/her/its designation of experts and provide written reports of such experts.
Page 2 | Expert Designations of Party Opposing Affirmative Relief
Parties seeking affirmative relief must serve their rebuttal-expert designations and provide written reports by the scheduling-order deadline.
Parties Initial Trial Setting seeking affirmative relief shall serve his/her/its designation of experts and provide written reports of such experts.
Page 2 | Designation of Rebuttal Experts
Amended pleadings asserting new claims, affirmative relief, or defenses must be filed with the court and served on all other parties by the scheduling-order deadline.
AMENDED PLEADINGS. 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
Parties must serve all other parties with amended pleadings asserting new causes of action or defenses by the stated deadline.
Parties shall file with the Court and serve all other ______________ parties with any amended pleadings asserting new causes of action or defenses no later (Date) than this date.
Page 1 | Amended Pleadings
Adjournment & Extension Requirements
A continuance or trial reset does not alter existing 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
A continuance or reset of the initial trial setting does not change existing deadlines unless the parties agree by Rule 11 or the court orders otherwise after a good-cause motion.
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