Harris County District Courts Filing Rules

A filing seeking relief must include a certificate of service, any TRCP-required certificate of conference, and a proposed order.

To withdraw a summary-judgment motion, file a written notice with the specified title and identify the motion’s original filing date.

The parties must prepare, exchange, and bring a Trial Notebook to the pretrial conference containing live pleadings, detailed witness lists, exhibit lists and copies, motions in limine and objections, deposition extracts and objections, and proposed jury charges.

Do not combine multiple motions in one proposed order.

In all cases, the parties must exchange the listed applicable trial documents at least 10 days before trial.

Contact the lead clerk by phone for matters relating to hearings and motions.

Ex parte communication about a pending or impending matter before the court is prohibited.

Hearings or submission matters before the 246th may be scheduled by emailing 246hearings@justex.net.

Jury-summons recipients may visit the district clerk’s website or call 713-755-6392 for information about their day of service.

An email or telephone call to the Clerk does not withdraw a summary-judgment motion or satisfy Rule 166a.

Applicable documents required under Rule 5.2.2 must be exchanged at least 10 days before trial.

Hearing dates must be selected within the court's 30-day scheduling window.

Replies filed after noon Friday for a Monday oral hearing are unlikely to be considered.

The judge must sign judgments and orders within seven working days after submission for entry, unless the court rejects them.

An MSJ set for oral hearing must be set between the 35th and 60th day after the motion is filed.

After making disclosure, a party must reasonably supplement or amend it upon obtaining information showing that it was incomplete or incorrect when made or is no longer complete or true.

Notice of submission setting must be served at least 10 days before the date of the hearing, or more if required by statute or rule.

The parties must receive written notice identifying the specific documents delivered to the Court as courtesy copies.

If an emergency hearing is granted, the movant must give proper notice to all parties.

If a courtesy copy is marked or highlighted, the submitting party must give all other parties an identical copy.

All hearings are held in person.

In some instances, the Court may require that longer or more complex proposed orders be emailed to the Clerk in Word format.

E-filed pleadings must have full un-abbreviated titles, labeled exhibits, and proposed orders must not be attached as exhibits.

In all divorces, a sworn inventory and appraisement must be pre-marked and submitted as an exhibit before the trial by default begins. (See Rule 6.4, above.)

Exhibits must be numbered and marked on the document, and each exhibit file’s title must match its pre-marked exhibit.

Rule 106 motions for substituted service are placed on the submission docket without a notice of submission.

Before the Court considers a motion requiring a conference, the movant must confer directly and person-to-person with opposing counsel.

Parties must confer before filing a discovery motion to attempt resolution without court intervention.

Default judgments are set on the submission docket, except when unliquidated damages must be proved up.

Agreed and unopposed motions need not be placed on the oral-hearing or submission docket.

A summary-judgment motion cannot be passed; the party must proceed or withdraw, and a reset request must comply with Rule 166a and is allowed only if that rule authorizes it.

Agreed continuance motions do not bind the Court and may be granted only at its discretion.

Parties should generally follow these guidelines in determining if extra time is required: Dispositive motions, summary judgment motions, and jurisdictional motions, requiring more than 20 minutes of total (for both the movant and all respondents) time for argument; All evidentiary hearings (other than defaults, minor settlements, or transfer of structured payments); and Pre-trial motions - including sanctions, discovery, and procedural motions - that will require more than 10 minutes of total (for both the movant and all respondents) time for argument.

To reschedule a case, the requesting attorney must prepare a reset agreement, obtain opposing counsel’s concurrence and Court approval, file the agreement with the District Clerk, and obtain future dates from the Coordinator or Judge before leaving the courtroom.

Motions for continuance should be filed as early as possible; motions filed after trial coordinator assignment are disfavored.

Pro se litigants set MSJ hearings on the Law Day Docket under 'Other Type of Motions' instead of the submission docket.

A party seeking an emergency hearing when the other side does not agree must e-file a motion for emergency hearing.

Litigants must electronically file documents with the Harris County District Clerk; hand-delivery or fax requires prior court authorization.

Electronic submission of the vacation letter form through the website is preferred, but not required.

Motion responses must be e-filed at least 48 hours before the hearing and must include a proposed order.

For deposition excerpts, deliver two hard copies (judge and court reporter) tabbed and in binders along with a USB thumb drive.

The Court does not accept paper or emailed courtesy copies; a party may call after e-filing to draw attention to a document, or, if a courtesy copy is absolutely necessary, provide it on a flash drive or disc.

A courtesy copy of any pleading filed within 24 hours of a hearing or submission date must be submitted.

A courtesy copy of the filing and exhibits is required if the pleading exceeds 20 pages or contains more than 50 exhibit pages.

A courtesy copy of the filing and exhibits is required when a pleading exceeds 20 pages or contains more than 50 pages of exhibits.

The parties are asked to work with opposing counsel or self-represented parties to narrow motion-in-limine issues by agreement.

All motions should have their own proposed order (Please do not combine multiple motions into one order).

Motions, responses, replies, exhibits, and proposed orders must each be filed as stand-alone documents, though they may be filed in the same envelope.

Do not split your documents into separate envelopes when filing.

Exhibits should be redacted before being offered; exhibits redacted after admission are marked as 'A' exhibits with the unredacted original kept by the court reporter, and any offered exhibit must be tendered to the court reporter.

Parties seeking to seal court records must comply with Texas Rule of Civil Procedure 76a.

Confidential information (such as reasons for withdrawal) may be filed under seal.

Confidential matters included in a motion to withdraw may be filed under seal.

Confidential matters in withdrawal motions may be filed under seal.

Motions requiring more than 30 minutes should request a special setting.

Emergency hearing requests must be made to the Court Clerk, with a filed and served letter or motion (max 2 pages) stating reasons for the hearing and emergency.

The Court encourages opportunities for lawyers practicing less than 4 years to participate in hearings or trials, especially when they drafted the underlying motion.