Dallas County Civil District Courts Pre-Motion Conference Requirements

Unliquidated default judgment motions require a prove-up hearing.

Motions for Default Judgments where damages are un-liquidated will require a prove-up hearing.

Required

Always

No motion may be filed unless accompanied by a Certificate of Conference; movant's counsel must make at least three attempts on at least two business days to confer with opposing counsel before filing.

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). Prior to the filing of a motion, counsel for the potential movant shall personally attempt to contact counsel for the potential respondent to hold or schedule a conference to resolve the disputed matters. Counsel for the potential movant shall make at least three attempts to contact counsel for the potential respondent. The attempts shall be made during regular business hours on at least two business days.

Required

Always

Before filing a motion, movant's counsel must make at least three attempts to contact respondent's counsel during regular business hours on at least two business days.

Prior to the filing of a motion, counsel for the potential movant shall personally attempt to contact counsel for the potential respondent to hold or schedule a conference to resolve the disputed matters. Counsel for the potential movant shall make at least three attempts to contact counsel for the potential respondent. The attempts shall be made during regular business hours on at least two business days.

Parties must conference in compliance with local rules before filing a discovery motion.

The Court expects parties to conference in compliance with local rules prior to making motion regarding discovery disputes.

Required

Always

Local Rule 2.07 requires a meaningful conference between opposing counsel before the Court will intervene.

Dallas Civil Courts Rule 2.07 requires a meaningful conference between opposing counsel prior to the Court's intervention.

Dallas Civil Courts Rule 2.07 requires a meaningful conference between opposing counsel before seeking the Court's intervention.

Dallas Civil Courts Rule 2.07 requires a meaningful conference between opposing counsel prior to the Court's intervention.

Counsel must meaningfully confer on discovery issues before any hearing is set.

Counsel must meaningfully confer on discovery issues and submit a Certificate of Conference that conforms to the Local Rules before any hearing is set.

Required

Always

A meaningful conference between opposing counsel is required before the Court will intervene, per Dallas Civil Courts Rule 2.07.

Dallas Civil Courts Rule 2.07 requires a meaningful conference between opposing counsel prior to the Court's intervention.

The Court will not conduct a Pre-Trial conference on matters the parties have not discussed and meaningfully attempted to resolve.

The Court will not conduct a Pre-Trial conference on matters the parties have not discussed and made a meaningful attempt to resolve.

Exhibits and motions in limine must be discussed with opposing counsel beforehand to seek agreements that may shorten the pretrial.

Please discuss those exhibits and any motions in limine with the opposing side beforehand to see if any agreements can be reached that can shorten the pretrial.

The certificate of conference requirement does not apply to dispositive motions, summary judgment motions, default judgments, and other listed motions.

Sections (a) and (b) of this Rule do not pertain to dispositive motions, motions for summary judgment, default judgments, motions to confirm arbitration awards, motions to exclude expert testimony, pleas to the jurisdiction, motions to designate responsible third parties, motions to strike designations of responsible third parties, motions for voluntary dismissal or nonsuit, post-verdict motions and motions involving service of citation.

Parties must diligently confer before bringing discovery disputes to the Court.

The Court expects the parties to diligently confer prior to bringing discovery disputes before the Court.

Parties must discuss exhibits and motions in limine with opposing side beforehand to seek agreements.

Please discuss those exhibits and any motions in limine with the opposing side beforehand to see if any agreements can be reached that can shorten the pretrial.

Agreed motions are typically set for submission; non-agreed motions are set for oral hearing.

If the Motions are agreed, they are typically set for submission. If the Motions are not agreed, they are set for oral hearing.