Judge Lauren Reeder
Individual Rules, Standing Orders & Policies
Adjournments
- First continuances are available for good cause or by agreement, and an agreed first continuance does not require a hearing unless the Court decides otherwise.
- Continuances after the third must show substantial need and must be set for an oral hearing whether agreed or opposed.
Request must include
Communication
Phone
Clerk
Document Filing Requirements19 rules
Discovery complaints must be filed by motion containing specified identification of the dispute, the parties' out-of-court discovery discussions, all counsel participating, and the discovery requests and responses.
The complaining party should file a motion containing: A brief description of the dispute; The date, time, and place doing the discussions have had out-of-court discovery; The names of counsel participating in the discussions; and A copy or verbatim reproduction of the discovery requests and responses at issue.
Document Type
Discovery Motion
A severance order must contain the case style and number, parties, documents, disposition status, and allocation of severance costs.
The order of the severance must contain the following information: Style of the case; Case number; Parties to be included in the severed case; Documents to be included; whether the severed case is disposed of or remains active; and the party paying for the costs of court and severance.
Document Type
Severance Order
Before any m to withdraw is considered, the attorney must file the enumerated list including notice of hearing, supporting statement, client information certificate, client notice letter, and acceptance or proof of service.
The following must be filed before any motion to withdraw as attorney of record will be considered: (1) Notice of hearing; (2) A statement of the particular circumstances and disciplinary rules requiring withdrawal; (3) A certificate by the attorney of the client's name, address, and telephone number, and a current statement; (4) A copy of a letter to the client giving the required notices; and (5) A signed acceptance of the letter or a proof of service of the letter.
Document Type
Motion To Withdraw
Persons preparing a certificate of conference must confer personally with opposing counsel or explain why they could not; sending a letter/email and receiving no response is insufficient.
The movant must confer person-to-person with opposing counsel before the Court will consider a motion that requires a conference. The Court will pass motions that do not have a certificate stating (1) that the movant has actually talked to opposing counsel, or (2) why counsel have not been able to discuss the motion. A certificate of conference stating that you sent a letter or email to opposing counsel and received no response is not a proper certificate of conference.
Document Type
Certificate Of Conference
If default service was made at a different address than stated in the citation, a motion to amend citation and proposed order to amend citation must be filed.
If the defaulting party was served at an address other than the address for which the citation was issued, the Court requires filing a Motion to Amend Citation, requesting that the citation be amended to reflect the actual address of service, along with a proposed Order to Amend Citation.
Document Type
Motion To Amend Citation
The substituted-service order must include and attach Exhibit A requiring specific mailing, return, and reporting provisions.
Additionally, the following must be referenced and attached as an exhibit to the order: EXHIBIT A ... (a) mailing by certified and regular mail, (b) return not made within 30 days after mailing, (c) return stating date and result, (d) attaching any returned envelope.
Document Type
Substituted Service Order
A certificate of election is required on all motions, pleas, and special exceptions except for specifically enumerated categories.
A certificate of conference is required on all motions, pleas and special exceptions except: Summary Judgments, Default Judgments, Agreed Judgments, Motions for voluntary dismissal or non-suit, Post-verdict motions; or Motions involving service of citation.
Document Type
Motion
Proposed orders must be filed with every motion and with every response to a motion.
File proposed orders with all motions and responses.
Document Type
Motion And Response
A notice or motion for non-suit in a case involving a minor must be filed without prejudice.
When a lawsuit involves a minor, any notice or motion for nonsuit must be filed without prejudice.
Document Type
Motion Or Notice Nonsuit
The motion response must include a proposed order with the e-filing.
E-file motion responses at least 48-hours before the hearing and include a proposed order.
Document Type
Motion Response
After obtaining a hearing date, a party must file a Notice of Oral Hearing and serve it on all counsel and pro se parties.
Once you obtain a hearing date you are required to file a Notice of Oral Hearing and serve it on all counsel or pro se parties.
Document Type
Notice Of Oral Hearing
All settlements involving minor children require a Guardian Ad Litem and the parties must submit an agreed motion and order for the GAL's appointment.
A Guardian Ad Litem will be required for all settlements involving minor children. The parties are to submit an Agreed motion and order for appointment of a Guardian Ad Litem.
Document Type
Agreed Motion And Order Gal Appointment
Each proposed order must be accompanied by a cover letter stating whether the order is agreed to as to form.
When submitting a proposed order, you must include a cover letter and indicate whether the proposed order is agreed as to form.
Document Type
Proposed Order
A continuance request that also asks to amend the docket control order must state in the motion and proposed order that a new scheduling order will be issued, or an amended scheduling order may be submitted.
If the parties would like to amend the docket control order in addition to continuing the trial date, please note your request in the Motion for Continuance and include the statement that a new scheduling order shall be issued by the Court in the proposed order. Alternatively, an amended scheduling order may be submitted.
Document Type
Motion For Continuance
In a default judgment motion, the movant must explain the damages calculation and provide supporting evidence.
When proving damages in a motion for default judgment, show the court how you calculated the figure and provide evidence to support your calculation.
Document Type
Motion For Default Judgment
Discovery proposed orders must list each discovery issue separately to enable specific rulings.
Proposed orders should list each discovery issue separately so that the court may sign a specific order granting or denying the requested relief.
Document Type
Discovery Proposed Order
In a default judgment motion, the fee affidavit must at minimum show experience, work performed, time spent, and hourly rate.
When proving attorney's fees in a motion for default judgment, in your affidavit provide the court with evidence to support your claim for attorney's fees. At a minimum you should show (1) your experience, (2) the work you did on the lawsuit, (3) how long it took you to do it and (4) your hourly rate.
Document Type
Default Judgment Fee Affidavit
Agreed or unopposed motions must be appropriately titled and must be signed by all parties or include a Certificate of Conference.
Agreed or unopposed motions should be titled as such and signed by all parties or include a Certificate of Conference.
Document Type
Agreed Motion
The proposed continuation order must provide a blank space for the Court to insert the new trial date.
The proposed order granting the continuance shall provide a space for the new trial date to be inserted by the Court.
Document Type
Proposed Continuance Order
Filing & Service rules
Electronic Filing Rules
Emergency hearing requests must be e-filed as an emergency motion with a detailed explanation of necessity.
In order to receive an emergency hearing, you must e-file an emergency motion that provides a detailed explanation of why it is needed.
Page 1 | EMERGENCY HEARING
Motion responses must be e-filed at least 48 hours before the hearing and must include a proposed order.
E-file motion responses at least 48-hours before the hearing and include a proposed order.
Page 1 | MOTION RESPONSES
Filing Timing and Cure Windows
A summary-judgment motion may not be set for hearing less than 35 days after the motion is filed.
All MSJ must be set no sooner than 35 days after the motion has been filed.
Page 1 | MOTIONS FOR SUMMARY JUDGMENT
A default judgment for unliquidated damages requires an oral hearing on Mondays at 10:30 AM with at least ten days' notice.
Default judgments asking for unliquidated damages will need an oral hearing on Mondays at 10:30am with a ten days’ notice.
Page 1 | MOTIONS FOR DEFAULT JUDGMENT
Most motions must receive at least 10 days' notice before being set on Monday's submission docket at 8:00 AM.
Submission docket takes place on Monday at 8:00 AM after 10 days’ notice for most motions.
Page 1 | Submission Docket
Motions to sever should be placed on the submission docket any Monday at 8:00 AM with ten days’ notice.
Motions for Severance should be set on the submission docket, any Monday at 8:00am with ten days’ notice.
Page 1 | MOTIONS TO SEVER
Service and Proof of Service Rules
In a default judgment, the movant must give the defaulting party and other appearing parties 10 days’ notice by regular and certified mail and must file a certificate of service.
The Court requires the movant to give the defaulting parties (as well as any other parties who may have made an appearance in the case) 10 days’ notice of the hearing and of the default motion by regular and certified mail, and to certify that this has been done in a certificate of service.
Page 1 | MOTIONS FOR DEFAULT JUDGMENT
Substituted service is complete upon compliance with the court's order even if the defendant does not sign the certified-mail receipt.
Service will be complete upon compliance with this Order regardless of whether Defendant signs the certified mail receipt.
Page 1 | RULE 106 MOTIONS FOR SUBSTITUTED SERVICE
Sealing & Redaction Procedures
Confidential matters included in a motion to withdraw may be filed under seal.
Confidential matters may be filed under seal.
Page 1 | Motions to Withdraw as Attorney of Record
Adjournment & Extension Requirements
Continuances after the third must show substantial need and must be set for an oral hearing whether agreed or opposed.
Continuations after the third continuance must demonstrate substantial need for a delay of the trial setting and must be set for oral hearing whether agreed or opposed.
Page 1 | CONTINUANCES
First continuances are available for good cause or by agreement, and an agreed first continuance does not require a hearing unless the Court decides otherwise.
First continuances may be granted for good cause or upon agreement if a motion for continuance is filed sufficiently in advance of the trial setting. If agreed, first continuances will not require a hearing unless after considering the motion the Court deems one necessary.
Chambers Communication Rules
An oral hearing date may be obtained by calling the court clerk at 832-927-2234.
Any party requesting an oral hearing can obtained a date by the clerk, please call the main number 832-927-2234.
Page 1 | HEARINGS
All counsel and the court clerk must be notified when a hearing is passed.
Please call the Court Clerk and all counsel when any hearing is passed.
Page 1 | HEARINGS
Before scheduling temporary-injunction hearings, movers must call the Court and state their readiness and the estimated length of the hearing.
Before scheduling hearings, movers should call the Court and notify the Court (1) regarding readiness to proceed with the hearing, and (2) the estimated length of the hearing.
Page 1 | Temporary Injunctions
Settlements may be announced by a phone call to the court coordinator or by email, without appearing in court.
You do not need to appear in court to announce a settlement; a phone call to the court coordinator is sufficient or an email from parties.
Page 1 | Settlements