Dallas County Civil District Courts Document Filing Requirements

Applies to

Motion

Must include

certificate of conference

Motions must have certificates of conference under Local Rule 2.07 or the clerk will not set them for hearing; summary judgment motions are excepted.

Motions without certificates of conference in compliance with Local Rule 6.01 will not be set for hearing by the clerk. Certificates of conference must be attached to all matters, except those excluded by Local Rules, i.e., motions for summary judgment.

Applies to

Jury charge

A working charge must be submitted to the Court at the pre-trial conference.

A “working” charge must be submitted to the Court at the pre-trial conference.

Applies to

Motion for continuance

Must include

proposed order

A continuance in a case under one year old requires only an agreed order submitted to the Judge.

Cases that are under a year old require only an agreed order to be submitted to Judge.

Applies to

Motion for continuance

Must include

proposed order

For cases over one year, all clients and attorneys must sign the continuance/proposed order, and a party's written consent is required even if counsel agree.

If a case is over one year old and all parties agree to a continuance, all clients and attorneys must sign the motion for proposed order. In accordance with the Local Rules, a actor’s written consent is required on cases that are more than a year old, even if the motion is agreed by all counsel.

Applies to

Motion for continuance

Continuances must be supported by affidavit unless all parties consent.

Continuances must be supported by a written statement, statement, unless stated to the consent is given by all parties.

Applies to

Temporary restraining order application

Must include

local rule certificate

TRO applications must include a certification that the case is not subject to transfer under Local Rule 1.06; if it is, counsel must advise the Court and the judge may refer the matter.

Counsel presenting any application for a temporary restraining order shall at the time the application is presented further certify that to the best of counsel's knowledge, the case in which the application is presented is not subject to transfer under Local Rule 1.06. If the case is subject to transfer, counsel shall fully advise the Court of the circumstances, particularly as to whether there has been any previous application for the same or similar relief or whether the relief sought will conflict with any other previous order, and the Judge to whom the application is presented may decline to act and refer the application or the entire case to the Judge of the Court to which the earlier related case is assigned.

Applies to

Proposed judgment

Must include

proposed order

Counsel must submit a proposed judgment or dismissal order within 30 days after a verdict, judgment, or written settlement announcement; failure to do so may result in dismissal with prejudice and costs.

Within 30 days after the Court has announced a verdict or judgment or the Court receives a written announcement of settlement from either party or from a mediator, counsel shall submit to the Court a proposed judgment or dismissal order, unless ordered otherwise. Failure to so furnish the Court with such a proposed judgment or dismissal order will be interpreted to mean that counsel wish the Court to enter an Order of Dismissal with prejudice with costs taxed at the Judge's discretion.

Applies to

Motion

Must include

certificate of conference

A Certificate of Conference must be one of the four verbatim paragraphs specified in Rule 2.07(c).

For the purpose of Rule 2.07(a), a "Certificate of Conference" shall mean the appropriate one of the following four paragraphs (verbatim):

Applies to

Application

No appointment will be made unless a current application is on file, unless all parties agree.

No appointments will be made without a current application on file unless agreed to by all parties.

Applies to

Pretrial order

Must include

certificate of conference

The pretrial order must include the parties' signed affirmation that they conducted a conference regarding the jury trial.

The parties signed below affirm that we have conducted a conference regarding the jury trial set in this Court on ____________ and have made the following agreements.

Applies to

Pretrial order

A Joint Pretrial Order is required for all cases lasting 3 days or longer.

The Court’s Joint Pretrial Order shall be required for all cases lasting 3 days or longer. It can be located on this Court’s website and must be submitted 2 days before the Pretrial Conference, or the Pretrial will be canceled.

Applies to

Motion to compel

Must include

certificate of conference

Motions to compel must include a certificate of conference and attach evidence of attempts to confer.

All Motions to Compel MUST contain a Certificate Conference. The Movant must show and attach attempts to conference with opposing counsel.

Applies to

Motion

Must include

certificate of conference

All motions must include a certificate of conference per Local Rule 2.07; motions without one will not be set for hearing, except where excluded (e.g., summary judgment motions).

Motions require Certificates of Conference as stated in Local Rules 2.07. Motions without Certificates of Conference in compliance with Local Rule 2.07 will NOT be set for hearing by the District Clerks office. Certificates of Conference must be attached to all motions, except those excluded by Local Rules, (i.e. Motions for Summary Judgment).

Applies to

Disclosures

Parties in delinquent ad valorem tax collection cases in Dallas County District Courts are exempt from the disclosure requirements of Tex. R. Civ. P. 194.1-194.4.

It is therefore hereby ORDERED that all parties in cases filed in the District Courts of Dallas County to collect delinquent ad valorem taxes pursuant to Texas Tax Code Sections 31-34 are exempt from the otherwise required disclosures set forth in Tex. R. Civ. 194.1 (“Duty to Disclose; Production”), 194.2 (“Initial Disclosures”), 194.3 (“Testifying Expert Disclosures”), and 194.4 (“Pretrial Disclosures”).

Applies to

Motion for leave

Must include

proposed order

A party seeking disclosures from another party must file a Motion for Leave to Request Disclosures and obtain a written order permitting the disclosures.

If a party desires to require another party to provide the aforementioned disclosures, such party must file a Motion for Leave to Request Disclosures and obtain a written Order permitting such.

Applies to

Original pleading

Attorneys filing a related case must disclose the relationship in the original pleading or a simultaneous filing, and failure to disclose constitutes certification that the case is not related.

The attorney filing a case that is so related to another previously filed case shall disclose in the original pleading or in a separate simultaneous filing that the case is so related and identify by style, case number and Court the related case. If no such disclosure is made, the signature of the attorney filing the case on the original pleading shall be that attorney's certification that the case is not so related to another previously filed case.

Applies to

Exhibits

All exhibits must be marked numerically or with letters before going on the record.

Please have all exhibits marked numerically or letters prior to going on the record.

Applies to

Appointment order

Each appointment must be made by a written order.

Each appointment is to be made by a written order.

Applies to

Fee approval order

Each fee payment approval must be made by a separate written order.

Each approval of the payment of a fee is to be accomplished by a separate written order.

Applies to

Motion for substitute service

Motions for substitute service under Rule 106 must be accompanied by an affidavit detailing verification efforts, service attempts, persons present, and a public record confirming residence.

All motions for substituted service under Rule 106 must be accompanied by an affidavit that includes the following information: 1. all efforts taken to verify that defendant actually lives or works at the subject address; 2. each attempt at service, with date(s) and time(s); 3. identity of persons who were present at the subject address and what was said; and 4. a printout of some public record or PublicData.com or similar online database confirming that the person to be served actually resides at the address at which service is being attempted.

Applies to

Non military affidavit

A DMDC printout must be included as an exhibit to the non-military affidavit in default judgment motions.

WarGames: No Defense Manpower Data Center (DMDC) printout as an exhibit to the non-military affidavit.

Applies to

Non military affidavit

When a DMDC search is conducted without a SSN, the non-military affidavit must include corroborating evidence that the individual is not in the military.

Saving Private Ryan: Conducting a DMDC search without a SSN (which is not bad in and of itself—just means the DMDC cannot authoritatively assert that this is the same individual that the query refers to) and not providing corroborating evidence in non-military affidavit that the individual is not in the military.

Applies to

Motion

The Board of Law Examiners fee acknowledgment letter must be included with the pro hac vice motion.

This acknowledgment letter will need to be included with the written motion to the Texas Court in which the out-of-state attorney is requesting permission to participate.

Applies to

Motion

Rule 106 motions for substitute service must be accompanied by an affidavit detailing verification efforts, service attempts with dates/times, persons present, and proof of residence.

All motions for substituted service under Rule 106 must be accompanied by an affidavit that includes the following information: 1. all efforts taken to verify that defendant actually lives or works at the subject address; 2. each attempt at service, with date(s) and time(s); 3. identity of persons who were present at the subject address and what was said; and 4. a printout of some public record or PublicData.com or similar online database confirming that the person to be served actually resides at the address at which service is being attempted.

Applies to

Return of service

The return of service must include a statement of the mailing dates and results for both certified and regular mail.

the return of service shall include a statement setting out the date of mailing and the result of the mailing by certified mail, and the date of mailing and result of same by regular mail (i.e., whether the envelope was returned by the post office, the green card came back signed, etc.); and

Applies to

Return of service

A copy of any envelope or green card returned by the post office must be attached to the return of service.

a copy of any envelope or green card returned by the post office shall be attached to the return of service.

Applies to

Exhibits

Parties are jointly responsible for preparing the jump drive with all admitted exhibits; non-admitted exhibits must not be included.

It is the joint responsibility of the parties to prepare the jump drive and ensure that it contains all admitted exhibits. No party shall include any exhibit on the jump drive that was not admitted into evidence by the Court.

Applies to

Defensive pleading

Attorneys answering a case must point out any failure of the filing attorney to make a proper disclosure of related cases.

The attorney answering any filed case shall point out in the original defensive pleading or in a separate simultaneous filing any failure of the attorney filing the case to have made a proper and accurate disclosure.

Applies to

Defensive pleading

If no failure is pointed out, the answering attorney's signature certifies the accuracy of the disclosure or that the case is not related.

In the absence of any such plea, the signature of the attorney filing the original defensive pleading shall be that attorney's certificate either that the disclosure of the attorney filing the case was accurate, or, if no disclosure was made by the attorney filing the case, that the case is not so related to a prior filed or disposed of case.

Applies to

Suggestion of bankruptcy

Parties must file a Suggestion of Bankruptcy with the clerk and serve copies on counsel within 20 days of receiving notice of another party's bankruptcy filing.

Any party to a pending case shall promptly notify the Court of the filing by any other party of a petition in bankruptcy. Such notice shall be made by filing a Suggestion of Bankruptcy with the clerk of the Court and serving copies on all counsel of record. The Suggestion of Bankruptcy shall be filed as soon as practicable, but in no event more than 20 days after a party receives notice of the filing of a petition in bankruptcy by any other party.

Applies to

Temporary restraining order

The TRO 2-hour notice requirement is waived if a verified certificate of party or counsel is filed showing irreparable harm is imminent or notice would impair the court's power to grant relief.

Compliance with the provisions of subparagraph a) hereof is not required if a verified certificate of a party or a certificate of counsel is filed with the application, 1) That irreparable harm is imminent and there is insufficient time to notify the opposing party or counsel; or 2) That to notify the opposing party or counsel would impair or annul the court's power to grant relief because the subject matter of the application could be accomplished or property removed, secreted or destroyed, if notice were required.

Applies to

Temporary restraining order

Counsel presenting a TRO application must certify the case is not subject to transfer under Local Rule 1.06 at the time of presentation.

Counsel presenting any application for a temporary restraining order shall at the time the application is presented further certify that to the best of counsel's knowledge, the case in which the application is presented is not subject to transfer under Local Rule 1.06.

Applies to

Proposed judgment

Must include

proposed order

Counsel must submit a proposed judgment or dismissal order within 30 days after verdict, judgment, or settlement announcement; failure results in dismissal with prejudice with costs at the Judge's discretion.

Within 30 days after the Court has announced a verdict or judgment or the Court receives a written announcement of settlement from either party or from a mediator, counsel shall submit to the Court a proposed judgment or dismissal order, unless ordered otherwise. Failure to so furnish the Court with such a proposed judgment or dismissal order will be interpreted to mean that counsel wish the Court to enter an Order of Dismissal with prejudice with costs taxed at the Judge's discretion.

Applies to

Motion

Must include

certificate of conference

No motion may be filed or set for hearing without a signed Certificate of Conference in one of the forms set out in Rule 2.07(c).

No counsel for a party shall file, nor shall any clerk set for hearing, any motion unless accompanied with a "Certificate of Conference" signed by counsel for movant in one of the forms set out in Rule 2.07(c).

Applies to

Certificate of conference

Certificate of Conference must use one of four verbatim forms specified in Rule 2.07(c).

For the purpose of Rule 2.07(a), a "Certificate of Conference" shall mean the appropriate one of the following four paragraphs (verbatim): (1) "Counsel for movant and counsel for respondent have personally conducted a conference at which there was a substantive discussion of every item presented to the Court in this motion and despite best efforts the counsel have not been able to resolve those matters presented."

Applies to

Motion

Must include

certificate of conference

Motions must include a certificate of conference certifying that counsel conferred or attempted to confer with opposing counsel, or that an emergency exists.

I, the undersigned attorney, hereby certify to the Court that I have conferred with opposing counsel in an effort to resolve the issues contained in this motion without the necessity of Court intervention, and opposing counsel has indicated that he does not oppose this motion.

Applies to

Motion

Must include

proposed order

Counsel seeking affirmative relief must tender a proposed order to the court at the commencement of any hearing on a contested matter.

Counsel seeking affirmative relief shall be prepared to tender a proposed order to the court at the commencement of any hearing on any contested matter.

Applies to

Motion

An attorney may withdraw only by motion and court order; the motion must be accompanied by the client's written consent or a certificate that another lawyer has been employed.

No attorney of record shall be permitted to withdraw from any case without presenting a motion and obtaining from the Court an order granting leave to withdraw. When withdrawal is made at the request of or on agreement of client such motion shall be accompanied by the client's written consent to such withdrawal or a certificate by another lawyer that he has been employed to represent the client in the case.

Applies to

Motion

Must include

proposed order

A motion must be filed as one lead document and the proposed order as a separate lead document, with the proposed order containing a cover letter or transmittal sheet as the lead document and the proposed order as an attachment.

The filing of a motion with the order at the bottom of the motion. You must file a motion as one lead document and a proposed order as a separate lead document. The proposed order should contain a cover letter and/or transmittal sheet as the lead document with the proposed order as an attachment.

Applies to

Answer

An answer and counterclaim must be filed as separate lead documents.

The filing of an answer and counterclaim. You must file the answer as one lead document and the counterclaim as a separate lead document.

Applies to

Notice of hearing

A fiat must be filed as a separate Notice of Hearing (not part of the pleading), containing the name of the associated pleading, with a cover letter or transmittal sheet as the lead document and the notice of hearing as an attachment.

A fiat should be filed as a separate Notice of Hearing and should not be part of the pleading, but should contain the name of the pleading associated to it. For example, Notice of Hearing on Motion for Continuance. The separate notice of hearing should contain a cover letter and/or transmittal sheet as the lead document with the notice of hearing as an attachment.

Applies to

Case cover sheet

A case cover sheet must be filed as a separate document from the lead document, not as an attachment to it.

A case cover sheet should be filed as a separate document from the lead document and not as an attachment to the lead document.

Applies to

Virtual hearing request

Must include

case number

Virtual room requests must include case number/style, hearing date, docket time, duration, subject, reset status, and participant email addresses.

Provide the following information in your request for the virtual room to be generated/setup from the Court Coordinator: Cause Number and Case Style? Date of the hearing? Time of the docket hearing? Duration of hearing for ALL sides? What is being heard on this setting? Is this request a reset/rescheduled of a previous hearing, which had NOT occurred or taken place? Email address for all persons expected to participate in the hearing.

Applies to

Reporters record request

Reporter's Record requests require the 134th Request form emailed to the Reporter.

When requesting a Reporter's Record, please fill out the 134th Request for Reporter's Record Form and email it to the Reporter at tina.thompson@dallascounty.org

Applies to

Attorney fees affidavit

The attorney's fees affidavit must state that the fees are both reasonable and necessary.

Beyond a Reasonable Doubt and Necessary Roughness: Improper proving up of fees in attorney’s fees affidavit: use of neither “reasonable” nor “necessary” or one and not the other, but not both as required at an absolute minimum.

Applies to

Proposed order

The proposed order must not seek attorney's fees for post-judgment collection efforts unless contractual or otherwise authorized.

The Debt Collector: Filing a proposed order that seeks attorney’s fees for post-judgment/collection efforts.

Applies to

Proposed order

The proposed order must condition appellate attorney's fees on an unsuccessful appeal by the defaulting defendant.

The Bad News Bears: Not conditioning an award of appellate attorney’s fees on an unsuccessful appeal by the defaulting defendant in the proposed order or the attorney’s fees affidavit.

Applies to

Proposed order

The proposed order must request 'taxable costs of court' rather than a specific amount.

The Blues Brothers: Asking for a specific amount to be awarded as costs, rather than just asking for “taxable costs of court” in both the proposed order and the motion for default judgment.

Applies to

Affidavit

The affidavit must state the legal basis for any departure from the standard interest rate.

The Departed: Filing a proposed order seeking an interest rate that departs from the standard—5%—currently under Texas Finance Code section 304.003, or 6% under Texas Finance Code section 302.002 in creditor/obligor suits—without stating in the affidavit and motion the legal basis for departing from the standard, such as a contractual interest rate.

Applies to

Affidavit

The affidavit must state the legal significance of the starting date for pre-judgment interest.

50 First Dates: Filing a proposed order seeking pre-judgment interest which accrues from a particular date without stating the legal significance of the date in an affidavit and motion.

Applies to

Motion

In TRCP 736 expedited foreclosure defaults, the motion must provide the proper paper trail from the original lender to the applicant.

The Paper Chase: With regard to TRCP. 736 Expedited Foreclosure Defaults, not providing the proper paper trail from the original lender to the applicant to show that the latter is entitled to an order allowing a foreclosure sale to go forward.

Applies to

Certificate of last known address

The certificate of last known address must contain the corporation's own last known address, not the agent's address.

21 Jump Street: Filing a certificate of last known address for a corporation containing an address that is not that of the corporation itself, but is, instead, the address of the agent designated for service of process.

Applies to

Damages affidavit

The damages affidavit must show the math used to calculate interest to be added to the principal.

The Count of Monte Cristo: Not showing in the damages affidavit the math used to arrive at the calculation of interest to be added to the principal.

Applies to

Application for appointment

No appointments will be made unless a current application is on file, except by agreement of all parties.

No appointments will be made without a current application on file unless agreed to by all parties.

Applies to

Appointment order

Each appointment must be made by a written order.

each appointment must be made by written order

Applies to

Fee approval order

Each fee payment approval must be made by a separate written order.

each approval of the payment of a fee must be accomplished by a separate written order

Applies to

Appointment or fee approval order

Orders for appointments or fee approvals must be specific enough for clerks to prepare monthly reports.

orders making appointments or approving the payment of fees are to be sufficiently specific to enable the clerks to prepare the required monthly reports.

Applies to

Appointment order

Appointment orders must include case number and style, name of appointee, position, relationship, and date of appointment.

CHECKLIST FOR APPOINTMENTS Case number and style Name of person or entity appointed Position to which appointed Relationship to ward or deceased, if relevant Indicate: Attorney, private professional guardian, public guardianship program or friend/family member Date of appointment

Applies to

Fee approval order

Fee approval orders must include case number and style, name, position, relationship, date of approval, source of fees, amount of fees, and if fees exceed $1,000, hours billed and expenses.

CHECKLIST FOR ORDERS APPROVING PAYMENT Case Number and Style Name of person or entity appointed Position to which appointed Relationship to ward or deceased, if relevant Indicate: Attorney, private professional guardian, public guardianship program or friend/family member Date of approval of fee Source of fees Amount of fees approved If fees exceed $1,000: Number of hours billed for work performed Billed expenses

Applies to

Attorney fees claim

The claim must attach a detailed list of dates worked, services performed, time, and expenses.

ATTACHMENT: ATTACH A DETAILED LIST OF DATES WORKED, SERVICES PERFORMED, TIME, AND EXPENSES.

Applies to

Appointment order

Every appointment made in a civil case, probate case, or proceeding governed by Titles 1, 2, or 4 of the Family Code, by a regular or assigned judge of any district court, constitutional county court, statutory county court, statutory probate court, court master or court referee of a person to a position for which any type of fee may be paid shall be made by written order.

Every appointment made in a civil case, probate case, or proceeding governed by Titles 1, 2, or 4 of the Family Code, by a regular or assigned judge of any district court, constitutional county court, statutory county court, statutory probate court, court master or court referee of a person to a position for which any type of fee may be paid shall be made by written order.

Applies to

Fee approval order

Fee payment applications must be approved by a separate written order.

Every application or request for the payment of a fee by such an appointee shall be approved by the court of the judge making the appointment. This approval shall be accomplished by a separate written order.

Applies to

Motion

Must include

proposed order

A proposed order must be filed with every motion before setting a hearing.

ORDERS MUST BE FILED WITH EVERY MOTION BEFORE SETTING A HEARING

Applies to

Motion

Must include

certificate of conference

Motions require a certificate of conference (per Local Rule 2.07), except summary judgment motions; the clerk cannot set a hearing without it.

Motions require certificates of conference as stated in Local Rule 2.07. Judge Moyé does not require a certificate of conference on motions for summary judgment. The clerk cannot set a hearing on a motion without a certificate of conference.

Applies to

Motion to release trust funds

A party receiving trust funds must provide a valid driver's license, certified birth certificate, and an affidavit of entitlement.

The party to receive the funds must provide a copy of a valid driver's license, certified birth certificate, and an affidavit stating that he or she is the person entitled to the funds.

Applies to

Exhibits

Exhibits must be pre-marked with stickers and chronologically numbered.

All exhibits must be pre-marked with exhibit stickers and chronologically numbered for ease of reference during remote proceedings.

Applies to

Motion

Must include

proposed order

A proposed order must be filed prior to the hearing.

The Court further requests that the parties have an proposed order filed prior to the hearing.

Applies to

Proposed findings conclusions

Parties must provide findings of fact and conclusions of law prior to the bench trial; amendments are allowed after evidence is presented.

the Court requires that the parties provide their findings of fact and conclusions of law prior to the bench trial and will allow parties to amend their findings of facts and conclusions of law after the evidence is presented.

Applies to

Exhibits

Exhibits must be pre-marked with exhibit stickers, chronologically numbered, and have sequentially numbered pages for ease of reference.

Any party needing to admit either exhibits or other evidence referred to above must electronically deliver same to the Court Reporter in PDF format in advance of the hearing already pre-marked with exhibit stickers and chronologically numbered for ease of reference (and directing a witness's attention) during remote proceedings. The pages of each Exhibit, deposition, declaration of other proffered evidence must be sequentially numbered for ease of reference.

Applies to

Agreed order

Must include

proposed order

When the L.R. 2.07 conference results in agreement, the moving party must submit an agreed order reflecting the agreement.

Whenever the L.R. 2.07 conference results in agreement between the parties, the Moving Party shall submit an Agreed Order reflecting agreement.

Applies to

Prove up submission

Must include

proposed order

Minor prove-ups require e-filing of an affidavit by the next friend, a written GAL report, broker's affidavit if applicable, proposed order approving GAL fees, and proposed final judgment.

This will require the following efiled documents: 1) an affidavit by the next friend; 2) a written GAL report (filed at least three working days prior to the hearing); 3) the broker’s affidavit if an annuity is being purchased; 4) a proposed order approving GAL fees signed off on by defense counsel; and 5) a proposed final judgment.

Applies to

Default prove up submission

Default prove-ups require e-filing of client's affidavit, 18.001 affidavits with records, and attorney's fees affidavit.

Plaintiff’s attorney shall e-file his client’s affidavit, 18.001 affidavits with records attached, attorney’s fees affidavit, etc. so that they are in the clerk’s record and the court can consider by submission.

Applies to

Final disposition

Must include

proposed order

After settlement, Plaintiff must file notice of nonsuit or proposed agreed final judgment; for minor children, file agreed motion to appoint GAL.

When a case has been announced settled, Plaintiff shall either file notice of nonsuit (with order) or a proposed agreed final judgment. When a settled case involves a minor child, parties shall file an agreed motion to appoint guardian ad litem (with order).

Applies to

Proposed order

Counsel must bring a printed copy of the proposed order to the hearing; e-filing does not satisfy this, and agreed orders must be signed on the last page.

Counsel for all parties are required to bring to the hearing a printed out copy of counsel's proposed order. This requirement is not satisfied by e-filing the proposed order. If an order is agreed as to form, the parties must sign the last page of the order.

Applies to

Notice of hearing

The notice of hearing must include the Zoom meeting ID.

Your notice should state: ZOOM, Meeting ID 941 9835 0765.

Applies to

Notice of hearing

The notice of hearing must instruct the other side to email a courtesy copy to the Coordinator at least 72 hours before the hearing.

Your notice should advise the other side to e-mail a courtesy copy (after it has been e-filed) to the Coordinator no less than 72 hours before the hearing.

Applies to

Discovery motion

Must include

certificate of conference

A Certificate of Conference conforming to the Local Rules must be submitted before any discovery hearing is set.

submit a Certificate of Conference that conforms to the Local Rules before any hearing is set.

Applies to

Motion for substituted service

Rule 106 motions for substituted service must be accompanied by an affidavit detailing service efforts, attempts, persons present, and proof of residence.

All motions for substituted service under Rule 106 must be accompanied by an affidavit that includes the following information: 1. All efforts taken to verify that defendant actually lives or works at the subject address; 2. Each attempt at service, with date(s) and time(s); 3. Identity of persons who were present at the subject address and what was said; and 4. A printout of some public record or PublicData.com or similar online database confirming that the person to be served actually resides at the address at which service is being attempted.

Applies to

Motion

Must include

certificate of conference

Each motion must comply with Certificate of Conference requirements.

Each motion must comply with the Certificate of Conference requirements of the Dallas County Local Rules.

Applies to

Trial announcement

Trial announcements are required even with a pending continuance motion and must state readiness, estimated trial length, and number of witnesses.

Trial announcements must be made, even if there is a pending Motion for Continuance. The trial announcement should state, ready or not ready. If ready, the announcement should provide the number of hours/days it will take to try the case and the number of witnesses etc.

Applies to

Motion

Must include

proposed order

Every motion must include a proposed order.

All motions must be accompanied by a proposed order.

Applies to

Motion

Multi-party non-suit motions must identify the non-suiting party and the parties remaining in the active case.

In multi-party cases, a motion for non-suit must identify the non-suiting party and the parties remaining in the active case.

Applies to

Motion to withdraw

Counsel withdrawing from a case must advise a corporate entity of its right to object and that only a Texas-licensed attorney may represent it in Court.

If counsel wishes to withdraw from a case, this Court strictly enforces Rule 10 of the Texas Rules of Civil Procedure and Local Rule 4.02. Contemporaneous with advising the corporate entity of its right to object to the withdrawal of counsel, counsel must advise the corporate entity that only an attorney licensed by the State of Texas can represent the corporate entity's interest in Court.

Applies to

Notice of hearing

Notice of hearing must include specific Zoom hearing language and link.

Your notice should state: “The hearing will be by ZOOM on _____________ , 202_ at _____ a.m./p.m. You may access the ZOOM link at https://txcourts.zoom.us/j/82836274342.”

Applies to

Motion

Must include

proposed order

Each party must file a proposed order before the hearing or submission date.

Each party must file a proposed ORDER before the hearing or submission date.

Applies to

Motion

Must include

certificate of conference

Motions must include a certificate of conference under Local Rule 2.07 or they will not be set for hearing.

Motions without certificates of conference in compliance with Local Rule 2.07 will not be set for hearing by the clerk. Certificates of conference must be attached to all motions, except those excluded by the Local Rules, i.e., motions for summary judgment.

Applies to

Proposed findings conclusions

Must include

proposed order

Parties must submit proposed judgments and proposed findings of fact and conclusions of law, with trial briefs on contested issues filed at the same time.

All parties must submit proposed judgments and proposed findings of fact and conclusions of law in accordance with the scheduling order but not less than seven 7 days of trial if not set forth in the scheduling order. Trial briefs on contested issues of law should be filed at the same time.

Applies to

Default judgment

Default judgment damages must be calculable from written instruments attached to the pleading; parties must substantiate their damages calculations.

In cases where damages are proved by affidavits, the Court must be able to calculate the proposed damages from written instruments attached to the pleading on which the default judgment is based. Therefore, parties must “show their work” to substantiate and support calculations, i.e., proposed damages.

Applies to

Notice of hearing

The notice of hearing must state the Zoom hearing date/time and the Zoom link.

E-file notice of hearing. Your notice should state: “The hearing will be by ZOOM on _____________ , 202_ at _____ a.m./p.m. You may access the ZOOM link at https://txcourts.zoom.us/j/82836274342.”

Applies to

Motion to withdraw

When a corporate party would be left without counsel, counsel must also advise the corporate party that it cannot represent itself pro se and only an attorney licensed in Texas can represent it in Court.

If the party that will be left without counsel (if the motion is granted) is a corporate entity, contemporaneous with advising the party of its right to object, counsel must also advise the corporate party that only a licensed representative in this State can represent its interest in Court. That is, that it cannot represent itself pro se.

Applies to

Brief or motion

Briefs and motions exceeding ten pages must include a table of contents, a table of authorities, and begin with a summary of the argument.

Briefs and Motions containing argument or authorities in excess of ten pages should have a table of contents and a table of authorities and begin with a summary of the argument.

Applies to

Brief

Only controlling case authority should be attached to briefs and motions; highlighted copies for opposing counsel must match the highlight manner provided to the Court.

ONLY copies of the case or cases which are controlling as to the issue the issue presented should be attached and provided to opposing counsel highlighted in the same manner as the Court's copy.

Applies to

Scheduling order

After a plea is answered, a scheduling conference is set; before it the parties must meet, agree on a trial date and mediator, stay within the trial range, and file a signed agreed scheduling order, or else all parties must appear.

Cases are set for a scheduling conference once a defendant has answered and made an appearance on a case. The parties are to confer before the conference, agree upon a trial date, agree upon a mediator, must be set within the trial range that is given on the scheduling conference notice and file an agreed scheduling order with all the parties' signatures. Failure to do so will require all parties to appear for the scheduling conference.

Applies to

Default judgment motion

Liquidated default judgments are submitted by motion and supporting affidavits, if any.

Default Judgments that are liquidated should only be submitted by motion and supporting affidavits, if any.

Applies to

Final trial announcement

Final trial announcements must include witness counts, estimated trial length, and any coronavirus symptoms among parties, witnesses, or attorneys.

At the time of announcement, the parties need to provide the following information: a. How many witnesses each side will call; b. Estimated length of the trial; and c. If any parties, witnesses or attorneys are exhibiting any symptoms associated with the coronavirus.

Applies to

Notice of hearing

For hearings held by telephone, the moving party must set up a call-in number and include it in the notice of hearing to the court and opposing counsel.

The moving party shall set up the call-in number and provide the number to the court and opposing counsel in its notice of hearing.

Applies to

Original pleading

Attorneys filing a case related to a previously filed case must disclose the relationship in the original pleading or a simultaneous filing, identifying the related case by style, case number, and court.

The attorney filing a case that is so related to another previously filed case shall disclose in the original pleading or in a separate simultaneous filing that the case is so related and identify by style, case number and Court the related case.

Applies to

Original pleading

If no related-case disclosure is made, the filing attorney's signature on the original pleading certifies that the case is not related to another previously filed case.

If no such disclosure is made, the signature of the attorney filing the case on the original pleading shall be that attorney's certification that the case is not so related to another previously filed case.

Applies to

Defensive pleading

The answering attorney must point out in the original defensive pleading or a simultaneous filing any failure by the filing attorney to make a proper and accurate related-case disclosure.

The attorney answering any filed case shall point out in the original defensive pleading or in a separate simultaneous filing any failure of the attorney filing the case to have made a proper and accurate disclosure.

Applies to

Defensive pleading

Absent a plea pointing out disclosure failures, the answering attorney's signature on the original defensive pleading certifies that the disclosure was accurate or that the case is not related to a prior filed or disposed of case.

In the absence of any such plea, the signature of the attorney filing the original defensive pleading shall be that attorney's certificate either that the disclosure of the attorney filing the case was accurate, or, if no disclosure was made by the attorney filing the case, that the case is not so related to a prior filed or disposed of case.

Applies to

Suggestion of bankruptcy

A party must promptly notify the Court of another party's bankruptcy petition by filing a Suggestion of Bankruptcy with the clerk and serving copies on all counsel of record.

Any party to a pending case shall promptly notify the Court of the filing by any other party of a petition in bankruptcy. Such notice shall be made by filing a Suggestion of Bankruptcy with the clerk of the Court and serving copies on all counsel of record.

Applies to

Agreed matter

Must include

proposed order, certificate of conference

Agreed matters do not require a separate motion or hearing but must be presented with a proposed order reflecting all parties' agreement by signature or certificate of conference; the rule does not apply to financial settlements involving minors.

The Court does not require a separate motion or hearing on agreed matters, except for continuances in cases over one year old or as otherwise provided. All uncontested or agreed matters should be presented with a proposed form of order and should reflect the agreement of all parties either (a) by personal or authorized signature on the form of order, or (b) in the certificate of conference on the motion. This Rule does not apply to cases involving financial settlements to minors.

Applies to

Application

This application form must be submitted every year.

THIS FORM MUST BE SUBMITTED ANNUALLY

Applies to

Case information sheet

Pro se litigants must select only one case type or issue on the Civil Case Information Sheet.

You must select only one case type or issue on the Sheet.

Applies to

Case information sheet

Pro se litigants must not check the Title IV-D Agency box on the Civil Case Information Sheet.

If you are representing yourself and you are the person completing the Civil Case Information Sheet, do not check the “Title IV-D Agency” box.

Applies to

Pretrial order

If the court must rule on page/line designations, attach transcripts with designations highlighted and only necessary pages.

If rulings are required from the court, please copy and paste and attach any transcripts with the designations highlighted, necessary pages only)

Applies to

Order

All agreed orders should be signed off by all parties.

All agreed Orders should be signed off by all parties.

Applies to

Default judgment order

Default judgment orders for liquidated damages must be submitted by motion with supporting affidavits; non-liquidated damages must be set for hearing or by affidavit.

Orders for Default Judgments may be submitted for consideration for liquidated damages as long as they are submitted by Motion and all supporting affidavits. Non-liquidated damages must be set for hearing or by affidavit.

Applies to

Notice of hearing

The notice of hearing must specify the method of hearing, and the requesting party must set up the CourtCall teleconference.

Telephonic hearings are allowed through Court Call. The notice of hearing must provide the method of hearing and the party must set up the teleconference with CourtCall.

Applies to

Brief

Briefs must highlight the issues and the relevant passages in the caselaw.

Please highlight the issues and highlight the relevant passages in the caselaw.

Applies to

Mediation notice

Parties opposing mediation must notify the Court of the reasons, and counsel must inform the Court if no mediator is agreed within 30 days after the trial notice is issued.

If the parties are opposed to mediation, they must notify the Court of the reasons for such opposition. It is Counsels responsibility to inform the Court if they have been unable to agree to a mediator 30 days after the trial notice has been issued.

Applies to

Motion to withdraw

Attorney withdrawals require strict compliance with TRCP Rule 10 and Local Rule 4.02, and counsel must advise a corporate party that only a Texas-licensed attorney can represent it in Court.

The Court requires strict compliance with Rule 10 of the Texas Rules of Civil Procedure and Local Rule 4.02. If the party that will be left without counsel (if the motion is granted) is a corporate entity, contemporaneous with advising the party of its right to object, counsel must also advise the corporate party that only an attorney licensed in the State of Texas can represent its interest in Court. That is, that it cannot represent itself Pro Se.

Applies to

Appointment and fee orders

Appointment and fee-approval orders must be specific enough for clerks to prepare the required monthly reports.

Orders making appointments or approving the payment of fees are to be sufficiently specific to enable the clerks to prepare the required monthly reports.

Applies to

Monthly report

Each court must report all appointments and payments made during the month, or submit a no-activity report if none were made.

For each court 1. All appointments made during the month OR report of no appointments made during the month AND 2. All payments approved during the month OR report of no payments made during the month

Applies to

No activity report

If no appointments were made during the month, submit a No Activity report indicating no activity for the month.

NO APPOINTMENTS MADE DURING MONTH Submit No Activity report indicating that there was no activity for the month for the court.

Applies to

No activity report

If no fees were approved during the month, submit a No Activity report indicating no activity for the month.

NO FEES APPROVED DURING MONTH Submit a No Activity report indicating that there was no activity for the month for the court.

Applies to

Report

Each reported payment must include all fees and expenses resulting from the appointment, including attorneys' fees, related expenses, and fiduciary compensation.

Each payment reported must include any and all fees occurring as a result of the appointment. It shall include attorneys’ fees and related expenses resulting from the appointment and any compensation and/or fees for serving as fiduciary.

Applies to

Report

The report must state the entire dollar amount approved for payment, not the hourly rate.

Dollar amount approved for payment. The entire amount should be reported, not the rate approved (i.e., not $15 per hour).

Applies to

Report

When total compensation paid to an appointee in one case exceeds $1,000 for the month, the report must include the number of hours billed and the total dollar amount of expenses billed.

If the total amount of compensation paid to an appointee for 1 case exceeds $1,000 for the month, report: 11. NUMBER OF HOURS BILLED The number of hours billed to the court for the work performed by the appointee or the appointee’s employees, including paralegals. 12. TOTAL BILLED EXPENSES The total dollar amount of expenses billed to the court for the work performed by the appointee or the appointee’s employees, including paralegals.

Applies to

Transcript request

All transcript requests must be made using the 'Requests for the Reporters' Records' form.

Please download and fill out the “Request for Request’s Records” form, and email ALL transcript requests for the Reporter’s Records forms to Tina Thompson at tina.thompson@dallascounty.org

Applies to

Protective order

The Court requires use of its standard Protective Order form when a protective order is needed.

In cases where the parties believe that a standard Protective Order is necessary, the Court requires that this form be utilized.

Applies to

Request for reporters record

Reporter's record requests require the 134th Request for Reporter's Record Form emailed to the reporter.

When requesting a Reporter’s Record, please fill out the 134th Request for Reporter’s Record Form and email it to the Reporter at tina.thompson@dallascounty.org

Applies to

Audio visual exhibits

Audio/visual exhibit file names must include the exhibit number and recording type; exhibits are delivered via Dropbox.

Audio/Visual file names should include the exhibit number and whether it’s a video or audio recording. Audio/Visual exhibits can be send to the Reporter via Dropbox - tina.thompson@dallascounty.org.

Applies to

Motion for substitute service

Must include

proposed order

Rule 106 motions should be accompanied by the attached proposed form order; failure to do so may delay granting.

Any Rule 106 Motion should be accompanied by the attached proposed form order. Failure to do so may delay the court's granting of an otherwise proper motion.

Applies to

Motion

Statements from neighbors or residents included in the affidavit must state the person's full name and a description.

Statements by neighbors or by people residing in the abode must include the full name of the person and a description.

Applies to

Motion

Must include

proposed order

Rule 106 motions should include the attached proposed form order; failure to do so may delay the court's granting of the motion.

Any Rule 106 Motion should be accompanied by the attached proposed form order. Failure to do so may delay the court's granting of an otherwise proper motion.

Applies to

Exhibits

The completed exhibit jump drive must be provided to the Court Reporter for delivery to the jury during deliberations.

The completed jump drive shall be provided to the Court Reporter so that it may be provided to the jury for their deliberations.

Applies to

Agreed matter

Must include

proposed order

Agreed matters require no separate motion or hearing but must be presented with a proposed order reflecting all parties' agreement by signature or certificate of conference.

The Court does not require a separate motion or hearing on agreed matters, except for continuances in cases over one year old or as otherwise provided. All uncontested or agreed matters should be presented with a proposed form of order and should reflect the agreement of all parties either (a) by personal or authorized signature on the form of order, or (b) in the certificate of conference on the motion. This Rule does not apply to cases involving financial settlements to minors.

Applies to

Proposed order

When the court directs counsel to prepare an order, it must be tendered to opposing counsel at least two working days before submission; opposing counsel must approve or file written objections, and failure to do so deems the order approved as to form.

Should the court notify counsel of its decision at any time following the hearing on any contested matter and direct counsel to prepare one or more orders for submission to the court any such order shall be tendered to opposing counsel at least two working days before it is submitted to the court. The opposing party must either approve the proposed order as to form or file objections in writing with the court. If an order is not approved as to form and no objections are [filed] order is deemed approved as to form.

Applies to

Brief

Briefs of ten or more pages must begin with a summary of argument.

Any brief that is ten or more pages long must begin with a summary of argument.

Applies to

Pleading

Every party pleading must include the information required by Texas Rule of Civil Procedure 57.

Every pleading of a party shall include the information required by Tex. R. Civ. P. 57.

Applies to

Motion

Must include

certificate of service

A copy of the letter must be attached to the motion, and a copy of the motion must be served on all counsel of record.

A copy of such letter shall be attached to the motion. A copy of the motion shall be served upon all counsel of record.

Applies to

Fee approval order

If fees exceed $1,000, fee approval orders must include number of hours billed and billed expenses.

If fees exceed $1,000: Number of hours billed for work performed Billed expenses

Applies to

Attorney fees claim

The verification must state that hours were figured to the nearest 1/10 and that the hours and expenses incurred were reasonable and necessary.

I have figured the hours to the nearest 1/10. The hours worked were reasonable and necessary. The expenses incurred were reasonable and necessary.

Applies to

Monthly fee report

Must include

judge name, case number

Clerks must prepare monthly reports of all fees of $500 or more approved for payment, including specified details.

At the end of each month, each district and county clerk shall prepare a report to include each fee approved during that month for payment in the amount of $500 or more. The report shall indicate: (1) the name of each person appointed by the judge of each district court, county court, statutory county court, and statutory probate court in the county to a position for which a fee of $500 or more has been approved during the month to be paid from any source; (2) the name of the judge approving the payment of the fees; (3) the case number and style of the case in which the fee was approved to be paid; (4) the date of the order approving the payment of the fee; (5) the position to which the person was appointed; and (6) whether the appointee is an attorney, a private professional guardian, associated with a public guardianship program, or a friend or family member of the ward or the deceased; and (7) the amount of the fee approved for payment, and the source of such payment.

Applies to

Motion

Excess page limits require leave of court upon compelling reasons; leave orders must list each document and its page length.

Permission to file a brief in excess of these page limitations may be granted with leave of the Court upon a showing of compelling reasons. Orders for leave must list each document and page length of each document to be filed.

Applies to

Demonstrative aids

Exhibits or demonstrative aids require opposing counsel's agreement or court approval obtained in sufficient time before Voir Dire.

Anyone wishing to use exhibits or demonstrative aids needs to obtain the agreement of opposing counsel or bring the question to the Court's attention in sufficient time to have the court consider the request prior to Voir Dire.

Applies to

Proposed order

Must include

proposed order

Parties should upload a proposed order reflecting their position at least two days before the motion hearing.

All parties involved in the hearing of a motion should upload a proposed order reflecting their position on the issues raised in the motion at least two (2) days prior to the hearing.

Applies to

Deposition notice

Depositions may be noticed to proceed remotely, and the notice must advise the witness/court reporter location and the ability of all counsel and others to participate remotely.

Any deposition in a case pending in this Court may be noticed to proceed technologically and remotely. Said notice shall specifically advise of the location of the prospective witness and the court reporter. The notice shall also advise all counsel of record and any other persons of the ability to participate remotely.

Applies to

Deposition notice

Deposition notices must explain how remote access will be effectuated, including dial-in or internet access codes.

Any notice shall additionally explain to all parties and interested persons/entities how the remote access to the proceedings will be effectuated, including dial-in or internet access codes.

Applies to

Jury instructions

Proposed jury charges must be emailed to the Court reporter prior to jury trial.

The Court prefers proposed jury charges to be sent to the Court reporter via email (Tenesa.Shaw@dallascounty.org) prior to jury trial.

Applies to

Ad litem application

Ad litems must contact the Court Coordinator and attach a CV and bio showing their qualifications to serve.

The Court requires that the ad litem reach out to the Court Coordinator and attach a CV and bio regarding their qualification to serve as an ad litem in civil cases.

Applies to

Attorney list

Parties must submit lists of all attorneys who will be present during voir dire.

The Court requests that parties submit lists of all attorneys who will be present during voir dire so that the Court may make an introduction.

Applies to

Motion for appointment of guardian ad litem

When the next friend does not speak English, the Motion for Appointment of Guardian Ad Litem must notify the Court that the GAL should be proficient in that language.

In cases when the next of friend of Plaintiff does not speak English, the parties shall notify the Court in the Motion for Appointment of Guardian Ad Litem that the Guardian Ad Litem should be proficient in the language spoken by the next friend.

Applies to

Protective order

Parties must use the form available on the Court's website for protective orders.

In cases when the parties believe that a Protective Order is necessary, the Court requires that the parties use the form that is available on the Court's website.

Applies to

Deposition notice

A notice of a remote deposition must advise of the witness and Court Reporter location, the ability to participate remotely, and include platform access information.

Deposition may be noticed to proceed technologically and remotely. Said Notice shall specifically advise of the location of the prospective Witness and the Court Reporter. It shall also advise all counsel of record and any other persons of the ability to participate remotely. 2. Any Notice shall include telephone number or other technological platform identification, access codes or other pertinent information to effectuate access to the proceedings by any interested individual or entity.

Applies to

Agreed order

When the L.R. 2.07 conference produces agreement, the moving party must submit an Agreed Order reflecting that agreement.

Whenever the L.R. 2.07 conference results in agreement between the parties, the Moving Party shall submit an Agreed Order reflecting agreement.

Applies to

Motion

Must include

proposed order

Parties must provide a proposed order with the requested relief.

The Court requests that parties provide a proposed order which provides the relief counsel is requesting from the Court.

Applies to

Brief

Cases relied upon should be attached to the brief with relevant provisions highlighted.

Cases relied upon should be attached to the brief with relevant provisions highlighted.

Applies to

Motion

Expedited hearing requests must explain the need, available dates/times for all parties, and time needed.

If there is a need for an expedited hearing, be prepared to explain the need for the "expedited" hearing, the dates, and times all parties are available for an expedited hearing, and the amount of time needed for such hearing.

Applies to

Scheduling order

Upon a granted continuance, parties must submit a revised scheduling order.

If the continuance is granted, the parties must submit a revised scheduling order based on the new trial date.

Applies to

Exhibits

All exhibits must be marked numerically or with letters before going on the record.

Please have all exhibits marked numerically or with letters prior to going on the record.

Applies to

Exhibit submission email

Exhibit submission emails must include the case number and style in the subject line, and the date of proceedings and attorney/party in the body.

Please include case number and style of the case in the subject line. In the body of the email, please also include the date of proceedings and which attorney/party they are being sent for.

Applies to

Deposition testimony

Video deposition testimony must be provided to the reporter in MP4 format with an excerpt transcript; deposition testimony in lieu of live testimony requires a complete transcript with page and line designations.

If video deposition testimony will be offered in lieu of live testimony, please provide the reporter with the video cuts in (1) MP4 format and (2) the excerpt deposition transcript that reflects the video cuts. If deposition testimony will be offered in lieu of live testimony, please provide the reporter with the complete transcript with page and line designations.

Applies to

Affidavit

The affidavit may include a statement of license plates in the driveway, and statements by neighbors or residents must include the declarant's full name and description.

This can also include a statement identifying license plates of cars in the driveway and attaching a printout of license plates registered to the person to be served. Statements by neighbors or by people residing in the abode must include the full name of the person and a description.

Applies to

Motion for substituted service

Must include

proposed order

Rule 106 motions should be accompanied by a proposed form order; failure to do so may delay the court's ruling.

It is highly recommended that all Rule 106 Motions be accompanied by the attached proposed form order. Failure to do so may delay the court’s granting of an otherwise proper motion.

Applies to

Return of service

The return of service must include a statement specifying the date and result of each mailing, both by certified mail and by regular first-class mail.

3. The return of service shall include a statement specifying the date of mailing and the result of the mailing by certified mail, and the date of mailing and result of same by ===== PAGE 2 ===== regular first-class mail (i.e., whether the envelope was returned by the post office, the green card was returned signed,

Applies to

Return of service

A copy of any envelope or green card returned by the post office must be attached to the return of service.

4. A copy of any envelope or green card returned by the post office shall be attached to the return of service.

Applies to

Deposition notice

Deposition notices must state the location of the witness and court reporter and advise all counsel and other persons of the ability to participate remotely.

Any Deposition may be noticed to proceed technologically and remotely. Said Notice shall specifically advise of the location of the prospective Witness and the Court Reporter. It shall also advise all counsel of record and any other persons of the ability to participate remotely.

Applies to

Deposition notice

Deposition notices must include the telephone number or other technological platform identification and access codes needed to join the proceedings.

Any Notice shall include telephone number or other technological platform identification, access codes or other pertinent information to effectuate access to the proceedings by any interested individual or entity.

Applies to

Agreed order

Must include

proposed order

If the LR 2.07 conference results in agreement, the moving party must submit an Agreed Order reflecting that agreement.

Whenever the L.R. 2.07 conference results in agreement between the parties, the Moving Party shall submit an Agreed Order reflecting agreement.

Applies to

Exhibits

All trial exhibits must be printed for jury deliberation.

All trial exhibits must be printed for jury deliberation purposes.

Applies to

Demonstrative aids

Slideshows and demonstrative aids must be included with exhibit submissions and remain confidential until published.

Please include any slideshows, PowerPoint presentations or other demonstrative aids that could potentially be screen-shared during these submissions. They will remain confidential until published by counsel and/or the parties.

Applies to

Exhibits

All exhibits must be marked numerically or with letters before going on the record; photographs should be marked separately.

Please have all exhibits marked numerically or with letters prior to going on the record. Photographs are best marked separately as their own exhibit for clarity purposes.

Applies to

Email

Exhibit submission emails must include case number and style in the subject line, and date of proceedings and attorney/party in the body; large exhibits should be discussed via email.

Please include case number and style of the case in the subject line. In the body of the email, please also include the date of proceedings and which attorney/party they are being sent for. If there is an exhibit that is unable to be transmitted via email due to size, please email me so we can discuss how best to submit it.

Applies to

Motion

Default judgment and substitute service motions are set by submission upon written request filed with the Court.

Hearings on Motions for Default Judgments or Motions for Substitute Service will be set by submission which will be scheduled upon written request filed with the Court.

Applies to

Motion

All motions other than default judgment and substitute service require in-person, hybrid, or Zoom hearings.

All other motions will require in person; hybrid; or zoom hearings.

Applies to

Motion to withdraw

Attorney withdrawal motions require strict compliance with TRCP Rule 10 and Local Rule 4.02, including advising a corporate party left without counsel that only a Texas-licensed attorney may represent it.

The Court requires strict compliance with Rule 10 of the Texas Rules Civil Procedure and Local Rule 4.02. If the motion is granted and the party that will be left without counsel is a corporate entity, contemporaneous with advising the party of its right to object, counsel must also advise the corporate party that only an attorney licensed in this State can represent its interest in Court. That is, a corporate entity cannot appear before the Court as a self-represented party.

Applies to

Jury questionnaire

Jury questionnaires must be pre-approved by Judge Frazier at the pre-trial conference and copies for the venire delivered to the Bailiff at least 3 business days before trial.

Parties may submit questionnaires, but they must be pre-approved by Judge Frazier during pre-trial conference. Copies for the jury venire must be delivered to the Bailiff of the Court at least three (3) business days before trial.

Applies to

Demonstrative aids

Demonstrative aids require Judge Frazier's approval and must be shown to opposing counsel before voir dire begins.

Demonstrative aids may be used only if approved by Judge Frazier and should be shown to opposing counsel before voir dire commences, to give counsel an opportunity to object.

Applies to

Motion

A request for oral hearing on a summary judgment motion must appear on the cover page of the Motion or Response.

All summary judgment motions will be set for hearing by submission on first available date at least 35 days after the motion is filed unless there is a request for oral hearing on the cover page of the Motion or Response.

Applies to

Motion to withdraw

To avoid the Court's consideration of a summary judgment motion, the movant must file a written motion to withdraw the motion and cancel the hearing.

In order to avoid consideration of the Motion for Summary Judgment by the Court, the movant must file a written Motion to Withdraw the Motion For Summary Judgment, and cancellation of the hearing.

Applies to

Motion to appear remotely

Parties located more than an hour from the court may appear remotely at dismissal hearings only after filing a motion to appear remotely.

Parties may appear remotely if they reside or office more than an hour from the court. In such cases, the party must file a motion to appear remotely.

Applies to

Motion to release trust funds

The party receiving trust funds must provide a valid driver's license, certified birth certificate, and an affidavit of entitlement.

The party to receive the funds must provide a copy of a valid driver's license, certified birth certificate, and an affidavit stating that he or she is the person entitled to the funds.

Applies to

Vacation letter

Must include

caption, case number

Attorneys may reserve up to three weeks of vacation per year by sending a vacation letter (with cause number and style) to the Court Coordinator and opposing counsel; once filed, no hearings, depositions, or trials may be set during reserved weeks except upon notice and hearing.

Any attorney may reserve up to three weeks in any calendar year for vacations by sending a "vacation letter" for each case (with appropriate cause number and style) to the Court Coordinator and opposing counsel, reserving weeks in which no hearings, depositions, or trials are set as of the date of the letter. Once a letter is on file, no hearings, depositions, or trials may be set during the reserved weeks except upon notice and hearing.

Applies to

Appearance

Counsel and self-represented persons appearing in Dallas County civil courts must acknowledge, by entering an appearance, that they have read and are familiar with the Local Rules, Rules of Decorum, and Texas Lawyers Creed.

All counsel and any self-represented person appearing in the civil courts of Dallas County shall by entering an appearance acknowledge that he or she has read and is familiar with these Local Rules, the Rules of Decorum set forth in Appendix 2, and The Texas Lawyers Creed set forth in Appendix 3.

Applies to

Case information sheet

If you are the person filling out the Civil Case Information Sheet and you do not have a lawyer, check this box.

If you are the person filling out the Civil Case Information Sheet and you do not have a lawyer, check this box.

Applies to

Pretrial order

Exhibits must be listed by number, not name, in the pretrial order.

Please list the exhibit numbers, not the name)

Applies to

Pretrial order

Motions in limine must be listed by number.

Please list the numbers

Applies to

Photographs

Photographs should be marked separately as their own exhibits for clarity on the record.

Photographs are best marked separately as their own exhibit for clarity purposes on the record.

Applies to

Appointment report

Must include

judge name, case number

For each appointment, the report must include court name/number, judge/master/referee, case number and style, state bar card number if attorney, appointee name, position appointed, relationship to ward or deceased if relevant, and date of appointment.

For each appointment, report: 1. NAME/NUMBER OF COURT 2. NAME OF JUDGE/MASTER/REFEREE ORDERING APPOINTMENT 3. CASE NUMBER AND STYLE OF CASE 4. STATE BAR CARD NUMBER OF APPOINTEE IF AN ATTORNEY 5. NAME OF PERSON APPOINTED 6. POSITION TO WHICH APPOINTED 7. RELATIONSHIP TO WARD OR DECEASED, IF RELEVANT 8. DATE OF APPOINTMENT

Applies to

Monthly report

Case style in reports may be abbreviated (e.g., last names only), and judges and clerks should use discretion regarding the style when party confidentiality is required.

The style may be abbreviated to include, for example, just the last names of the parties. In matters where confidentiality of the parties is required, judges and clerks should use their discretion regarding the style of the case.

Applies to

Payment report

Must include

judge name, case number

For each fee approved, the report must include court name/number, judge/master/referee approving payment, case number and style, state bar card number if attorney, appointee name, position appointed, relationship to ward or deceased if relevant, and date of fee approval.

For each fee approved, report: 1. NAME/NUMBER OF COURT 2. NAME OF JUDGE/MASTER/REFEREE APPROVING PAYMENT 3. CASE NUMBER AND STYLE OF CASE 4. STATE BAR CARD NUMBER OF APPOINTEE IF AN ATTORNEY 5. NAME OF PERSON APPOINTED 6. POSITION TO WHICH APPOINTED 7. RELATIONSHIP TO WARD OR DECEASED, IF RELEVANT 8. DATE OF APPROVAL OF FEE

Applies to

Payment report

Report the date the approval order was signed, or the payment date if the compensation amount was not specified in the approval order.

DATE OF APPROVAL OF FEE Date the approval order was signed (or the date the payment was made if the amount of compensation was not specified when the approval order was signed).

Applies to

Motion for substitute service

The affidavit may also include license plate information, and statements by neighbors or residents must include the person's full name and a description.

This can also include a statement identifying license plates of cars in the driveway and attaching a printout of license plates registered to the person to be served. Statements by neighbors or by people residing in the abode must include the full name of the person and a description.

Applies to

Exhibits

The Court Reporter retains the exhibit jump drive for preparing the record on appeal.

The jump drive will be retained by the Court Reporter, who shall use it for purposes of preparing the record in connection with any appeal.

Applies to

Default judgment

Default prove-ups may be made through affidavits without a hearing upon the Court's request.

Upon request by the Court, default prove-ups may be made through affidavits and without hearing.

Applies to

Jury questionnaire

Jury questionnaires must include a blank space for prospective jurors to note hardships or problems with the estimated trial length.

We suggest a one page form except in exceptional circumstances and the form should have a blank space or a specific place for the prospective juror to note any hardships or problems in staying the estimated length of the trial.

Applies to

Brief

Briefs should be organized, concise, and address the most pressing issues first.

The Court prefers briefs to be organized and concise addressing the most pressing issues first.

Applies to

Jury instructions

For complex cases, the Court will ask the parties to submit and blue line/red line the jury charge.

If the case is complex, the Court will ask the parties to submit and blue line/red line jury charge.

Applies to

Motion

Briefs should be incorporated into the motion.

The Court prefers that the brief be incorporated into the motion.

Applies to

Pretrial items

The Court prefers that parties exchange and discuss pretrial items (Motions in Limine, witness lists, deposition designations, exhibits) before the hearing.

At pre-trial conferences, you will be dealing with Motions in Limine, witness lists, deposition designations and exhibits. The Court prefers that both sides exchange and discuss these items prior to the hearing and reach any agreements.