Harris County District Courts Filing Rules

Requests to the court must be made in a written motion.

Attorneys must identify themselves to the Judge and court reporter before a hearing and provide a business card with contact details and party representation.

Both parties must agree to a preferential setting request and file a motion with the court.

Notices of hearings must include the court's permanent Zoom link.

All exhibits must be premarked before trial and exhibit list copies provided to the judge, court reporter, and opposing counsel.

When scheduling a hearing, parties must give the Clerk of the Court an accurate estimate of the time the hearing will require.

Self-represented litigants must not communicate privately (ex parte) with the judge; such communications are returned unread, while formal pleadings and motions filed with the clerk are permitted.

Arrangements for acquiring testimony may be made directly with the court reporter; advise a week in advance if a daily copy is required, notify the other side, and contact via email or phone.

Proposed jury charges must also be emailed directly to the Trial Coordinator.

Questions about remote hearings should be directed to clerk Dee Mosley by phone or email.

Self-represented litigants should arrive at least thirty minutes early for court to allow time for parking, security, and locating the courtroom.

Parties must exchange and file exhibit lists, motions in limine, deposition offers, and proposed jury charges or proposed findings of fact and conclusions at least 3 days before trial (or the Thursday before a Monday trial setting).

Summary judgment motions must be heard within 60 days of filing or be automatically denied without prejudice.

Daubert motions must be filed and set for hearing well in advance of trial; motions filed after the docket control order deadline will not be considered without leave showing exceptionally good cause.

Motions to exclude experts must be filed and set for hearing at least 30 days before trial.

Exhibits must be marked with party-specific stickers using numbers only (not letters), and parties must provide their own stickers.

Exhibits over 30 must be scanned to a CD with specific resolution and pixel requirements.

Exhibits filed with the Court must be indexed.

A draft of the proposed jury charge must be exchanged before pretrial, delivered in Word format to the court coordinator via email or via thumb drive.

No continuances will be granted to move from a preferential setting except for death or serious illness of a party/lead counsel or an immediate family member; witness unavailability is not grounds for a continuance.

Summary judgment hearings cannot be continued via email or phone; withdrawal requires a notice and proposed order, and resetting requires an affidavit or declaration explaining the need.

All continuance or reset motions, whether agreed, unopposed or opposed, must state which number continuance is being filed (e.g., 'Plaintiff's First').

The Court will generally allow one continuance; a first or second request must be filed 24 hours before docket call, other requests require a hearing, and an reasonable explanation is required.

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.

Self-represented litigants must serve a copy of every pleading filed with the court on the opposing attorney or party.

Parties must exchange all exhibits before trial.

Pro se litigants must send a copy of every pleading filed with the court to the opposing party or their attorney.

Substituted service is complete upon compliance with the court's order even if the defendant does not sign the certified-mail receipt.

A copy of every pleading filed with the court must be sent to the opposing attorney or party.

The listed motions are set on the Tuesday 11:00 AM submission docket and are ruled on without an appearance.

Summary judgment motions are heard by submission unless a party requests a hearing.

Failure to actually confer or adequately explain unsuccessful attempts may result in the motion being removed from the docket.

Parties must consult with each other before seeking an emergency hearing, preferably lead attorney to opposing lead attorney.

All documents must be filed electronically through efiletexas.gov except as permitted by the Texas Supreme Court's e-filing rules.

A party claiming an emergency must e-file a motion for emergency/expedited hearing and send a courtesy copy to the Clerk.

Emergency hearing requests must be e-filed as an emergency motion with a detailed explanation of necessity.

Hard copies of the exhibit list and exhibits must be delivered to the Judge and court reporter 2 business days before proceedings, and multi-page exhibits must be stapled or bound.

The Court does not accept paper or e-mailed courtesy copies; parties should e-file and call the Court to flag the document, bringing a paper copy only if a courtesy copy is truly necessary.

Courtesy copies of motions, responses, or exhibits should not be submitted to the Court.

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.

Exhibit redactions must be made before the exhibit is offered; exhibits redacted after admission are marked as 'A' exhibits with the unredacted original kept by the court reporter.

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.

Motions expected to last more than 30 minutes should be set by special setting.