Court Rules

Harris County District Courts Document Filing Requirements

80 rules from official source documents

Required elements, certificates, and structural requirements for court documents. This page is scoped to Harris County District Courts; use the court rules overview to switch categories without leaving this court.

Applies to
Exhibits

Redaction of exhibits must be completed before arriving for trial.

Any exhibits that need to be redacted MUST be done prior to the time you arrive for the beginning of trial.

Judge Kyle CarterCRITICAL
Applies to
Motion
Must include
proposed order

All motions and responses must include a proposed order.

All motions and responses must include a proposed order.

Judge Latosha Lewis PayneCRITICAL
Applies to
Motion
Must include
certificate of conference

A detailed certificate of conference is required for all motions except enumerated types; noncompliance may cause the court to pass the hearing.

You must confer with your opposing counsel prior to filing all motions and include a detailed certificate of conference, with the following exceptions: motions for default judgments, motions for summary judgment, motions to dismiss, plea to jurisdiction, motions to transfer venue, motions for voluntary dismissal/ nonsuits, post-verdict motions, special appearances, and motions involving service of process. Failure to comply may result in the Court passing the hearing.

Judge Latosha Lewis PayneCRITICAL
Applies to
Discovery motion
Must include
certificate of conference

Discovery motions and discovery hearing requests must include a certificate stating a reasonable effort to resolve the dispute was made and failed.

The Court requires compliance with Texas Rule of Civil Procedure 191.2, which states as follows: “Parties and their attorneys are expected to cooperate in discovery and to make any agreements reasonably necessary for the efficient disposition of the case. All discovery motions or requests for hearings relating to discovery must contain a certificate by the party filing the motion or request that a reasonable effort has been made to resolve the dispute without the necessity of Court intervention and the effort failed.”

Judge Latosha Lewis PayneCRITICAL
Applies to
Default judgment motion
Must include
certificate of service

Default judgment motions require an oral hearing, proof of service of the hearing notice, a certificate of last known address, and a non-military service affidavit.

All motions for default are heard in an oral hearing only. Default motions are heard at 9:30 a.m. (with live testimony) and 9:45 a.m. (all others) on Monday. A certificate of service providing proof of service of a notice of hearing to the non-movant(s) must accompany all Default motions. A separate certificate of last known address and a proper non-military service affidavit must be attached to the motion. A non-military verification may be obtained by visiting the Defense Manpower Data Center’s (DMDC) Military Verification service at https://scra.dmdc.osd.mil.

Judge Latosha Lewis PayneCRITICAL
Applies to
Motion to withdraw

A motion to withdraw that leaves a pro-se client must include a notice of the hearings, factual statement of circumstances, the counsel certification with client contact information, a detailed client letter, and the client's acceptance or proof of consent.

Before consideration of a motion to withdraw that will leave a client as self-represented, the following must be processed file: Notice of hearing or submission. A statement of the particular circumstances and disciplinary rules requiring withdrawal. A general statement of “irreconcilable conflicts” is not enough. A certificate by the counsel of record of the client's name, address, and telephone number, a expertise that information is current or was last known to be current along with email details. A copy letter informing the client of the fact of withdrawal, that the client is covered by the Texas Rules, that notices to the client's present address will be deemed, that no continuances will be granted to assist new counsel, and the hearing or submission date. Association the notices. Of the attorney giving the client notice theories, that all notices from the Court to the client address will be considered, no extensionerners will be granted to the client, and the motion's hearing or submission date. A signed acceptance if the client has agreed; and if the client has not agreed, proof of service of the letter.

Judge Latosha Lewis PayneCRITICAL
Applies to
Motion response
Must include
proposed order

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.

Judge Lauren ReederCRITICAL
Applies to
Notice of oral hearing
Must include
certificate of service

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.

Judge Lauren ReederCRITICAL
Applies to
Motion
Must include
certificate of conference

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.

Judge Lauren ReederCRITICAL
Applies to
Certificate of conference

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.

Judge Lauren ReederCRITICAL
Applies to
Motion and response
Must include
proposed order

Proposed orders must be filed with every motion and with every response to a motion.

File proposed orders with all motions and responses.

Judge Lauren ReederCRITICAL
Applies to
Discovery motion

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.

Judge Lauren ReederCRITICAL
Applies to
Motion or notice nonsuit

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.

Judge Lauren ReederCRITICAL
Applies to
Motion to withdraw
Must include
certificate of service

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.

Judge Lauren ReederCRITICAL
Applies to
Substituted service order
Must include
exhibit list

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.

Judge Lauren ReederCRITICAL
Applies to
Agreed motion and order gal appointment
Must include
proposed order

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.

Judge Lauren ReederCRITICAL
Applies to
Motion to amend citation
Must include
proposed order

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.

Judge Lauren ReederCRITICAL
Applies to
Severance order

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.

Judge Lauren ReederCRITICAL
Applies to
Motion or other document requesting relief
Must include
proposed order, certificate of service, certificate of conference

Every motion or document asking the Court for relief must include a certificate of service, a certificate of conference (as required by TRCP), and a proposed order.

File your motion or other document with a certificate of service, (include certificate of conference as required by the TRCP) and a proposed order each time you ask the Court to grant or deny relief.

Judge Sonya L. AstonCRITICAL
Applies to
Motion
Must include
certificate of conference

Motions must include certificates of conference that explicitly describe the party's efforts to resolve the motion with all other parties before filing.

Motions must have certificates of conference as required by the Texas Rules of Civil Procedure and our local rules. All certificates of conference must be explicit as to the party's efforts to resolve the motion with all other parties/counsel prior to filing.

Judge Sonya L. AstonCRITICAL
Applies to
Discovery motion
Must include
certificate of conference

Discovery motions and discovery hearing requests must contain a certificate that a reasonable effort to resolve the dispute was made and failed (TRCP 191.2).

All discovery motions or requests for hearings relating to discovery must contain a certificate by the party filing the motion or request that a reasonable effort has been made to resolve the dispute without the necessity of Court intervention and the effort failed.

Judge Sonya L. AstonCRITICAL
Applies to
Motion
Must include
certificate of conference

Certificates of conference are required for all motions, pleas, and special exceptions except summary judgments, default judgments, agreed judgments, voluntary dismissals/non-suits, post-verdict motions, and motions involving service of citation.

The certificates of conference required by the TRCP are extended to all motions, pleas and special exceptions except summary judgments, default judgments, agreed judgments, motions for voluntary dismissal or non-suit, post-verdict motions and motions involving service of citation.

Judge Sonya L. AstonCRITICAL
Applies to
Default judgment motion

Default judgment motions must include a non-military affidavit obtained from the DMDC Military Verification service.

Please submit the proper non-military affidavit by visiting the Defense Manpower Data Center's (DMDC) Military Verification service at https://scra.dmdc.osd.mil.

Judge Sonya L. AstonCRITICAL
Applies to
Default judgment motion and proposed judgment

Default judgment motions and proposed judgments must state whether the judgment is final or interlocutory.

Please make clear in your motion and proposed judgment whether the judgment will be final (disposing of all claims and all parties) or interlocutory (partial).

Judge Sonya L. AstonCRITICAL
Applies to
Severance motion and order

Severance motions and orders must include the new case number/court/case type/style, reference to parties, list of pleadings to be severed with document details, attorney information for costs, and whether the severed case is interlocutory or final and appealable.

All motions AND orders for severance MUST contain the following: New case number, court number, case type and new style name; Reference the parties in the new suit; List of original pleadings to be severed out and transferred to the new case (together with a listing of the document type, activity date for the document, number of pages and image number); Indicate attorney name, address and bar number to whom costs for the severance are to be assessed; and Indicate the severance case's status, and whether the new case file is interlocutory (not a final appealable matter) or whether severance will cause the newly severed matter to be final and appealable upon severance.

Judge Sonya L. AstonCRITICAL
Applies to
Rule 106 substitute service motion

Rule 106 substitute service motions must include an affidavit showing address verification efforts, at least 6 service attempts (2 before 7:30 AM and 2 after 6:00 PM), persons present and what was said, and a printout confirming residence.

All motions for substituted service under Rule 106 must be accompanied by an affidavit that includes the following information: Efforts taken to verify that defendant actually lives or works at the subject address; Each attempt at service, with date(s) and time(s)A total of 6 attempts. Must have at least 2 before 7:30 AM and 2 after 6:00 PM. Identity of persons who were present at the subject address and what was said; and A printout of some public record or Public Data.com or similar online database confirming that the person to be served actually resides at the address at which service is being attempted.

Judge Sonya L. AstonCRITICAL
Applies to
Trial or pretrial continuance motion

Trial or pretrial continuance motions must be accompanied by an appropriate affidavit unless agreed, and should be filed early.

Motions for trial or pretrial deadline continuances MUST to be accompanied by an appropriate affidavit, unless they are agreed. Continuance motions should be filed early.

Judge Sonya L. AstonCRITICAL
Applies to
Motion to withdraw as attorney

Motions and proposed orders to withdraw as attorney must show notice to the client with evidence of mailing, client consent status, client contact information, notice of the client's right to object, and reasonable efforts to find substitute counsel.

All motions AND proposed orders to withdraw as attorney of record MUST contain the following: An indication that the motion to withdraw and notice of the hearing or notice of submission was provided to the client, including evidence of mailing the motion to the client; An indication of whether or not the client consents to the motion; The last known mailing address, email, phone and fax number of client; and Notice to client that client has the right to appear at the hearing to object to the motion or file a response prior to the submission of the motion; Please make reasonable efforts to find substitute counsel in the appropriate case so that the client's interests are protected;

Judge Sonya L. AstonCRITICAL
Applies to
Motion to withdraw as attorney
Must include
certificate of conference

Motions to withdraw as attorney of record require a certificate of conference.

These motions DO require a certificate of conference, as opposing counsel has a right to be heard on these motions.

Judge Sonya L. AstonCRITICAL
Applies to
Final order

Final orders must expressly state that they dispose of all claims and all parties and are intended to be final and appealable.

Final orders MUST state that the order disposes of all claims and all parties and is intended to be a final, appealable order.

Judge Sonya L. AstonCRITICAL
Applies to
Notice of hearing
Must include
certificate of service

Opposed matters require scheduling a hearing and filing a notice of hearing with a certificate of service; otherwise the court will not rule.

If your matter is opposed and you do not schedule your hearing and file a notice of hearing with a certificate of service, the court will not make a ruling.

Judge Tamika Craft-DemmingCRITICAL
Applies to
Motion

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

Your requests to the court should be made in a written motion.

Judge Beau A. MillerWARNING
Applies to
Business card

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

Identify yourself to the Judge and the court reporter before a hearing begins. Provide a business card with your name, correct address, phone number, fax number and e-mail address. Also include party representation.

Judge Cheryl Elliott ThorntonWARNING
Applies to
Deposition designations

Deposition page/line designations and a non-condensed transcript copy must be furnished to the court reporter before the offer, and readers must announce 'Question' and 'Answer' when reading deposition testimony.

Page/line designations of deposition testimony, along with a non-condensed copy of the transcript, are to be furnished to the court reporter prior to the offer. When one person is reading from written deposition testimony, the reader must say “Question” prior to reading each question and “Answer” prior to reading each answer.

Judge Cheryl Elliott ThorntonWARNING
Applies to
Motion

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

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

Judge Christine WeemsWARNING
Applies to
Motion

The Motion to Request a Preferential Setting must include the basis for the preferential setting (e.g., out-of-town witnesses, trial will take two weeks or longer).

The Motion to Request a Preferential Setting must include the basis for the preferential setting (i.e out of town witnesses, will take two (2) weeks or longer to try.)

Judge Christine WeemsWARNING
Applies to
Motion

By requesting a preferential setting, counsel agrees to waive all vacation letters for that time period.

Counsel understands that by requesting a preferential setting, they agree to the following:To waive all vacations letters for that time period.

Judge Christine WeemsWARNING
Applies to
Guardian ad litem application

Applicants for the guardian ad litem list must submit a written request with a complete resume detailing their civil trial experience and any special capabilities.

Those wishing to be included in the Court’s list must submit a written request with a complete resume that details the nature of the applicant’s experience as a civil trial practitioner. Special capabilities, such as fluency in languages other than English, financial background, and the like, should also be listed.

Judge Christine WeemsWARNING
Applies to
Guardian ad litem application

Guardian ad litem applicants must affirm that professional liability coverage is in effect and will remain current.

Applicants must also affirm that professional liability coverage is in effect and will remain current.

Judge Christine WeemsWARNING
Applies to
Exhibits

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

PLEASE HAVE ALL EXHIBITS PREMARKED BEFORE TRIAL AND A COPY OF YOUR EXHIBIT LIST FOR THE JUDGE, THE COURT REPORTER AND OPPOSING COUNSEL BESIDES THE ONE FILED IN YOUR PRETRIAL ORDER.

Judge Kyle CarterWARNING
Applies to
Motion

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

Your requests to the court should be made in a written motion.

Judge Latosha Lewis PayneWARNING
Applies to
Certificate of conference

Certificates of conference must detail the movant's resolution efforts, describe attempts to communicate when opposing counsel could not be reached, and be supplemented after actual conferrence.

The certificate of conference should include a detailed statement of the movant's efforts to resolve the issues in the motion with opposing counsel/party prior to filing the motion. If a party was unable to reach the other side prior to filing the motion, the certificate should state the efforts to communicate with that party, and should always be supplemented as soon as possible after the parties have actually conferred and before the hearing on the motion.

Judge Latosha Lewis PayneWARNING
Applies to
Certificate of conference

Vague statements about unreturned calls or unanswered letters do not satisfy the certificate of conference requirement.

The Court does not consider the following statements, or the like, to comply with the Rule: “Sent a letter…did not get a response” “Left a message…don’t know if the other side agrees or disagrees.” “The other side won’t return my phone calls.” “I have attempted to resolve this matter by agreement but was unable to do so.”

Judge Latosha Lewis PayneWARNING
Applies to
Motion for substituted service
Must include
proposed order

Substituted service motions require a detailed affidavit and the court's attached form order, and are decided without a hearing.

Motions for substituted service are submitted to the Court for consideration without the need for a hearing. The motion should include an affidavit (a) detailing all efforts taken to verify that the defendant actually lives or works at the subject address, (b) multiple attempts of service at different times of day with the specific dates and times, (c) the identity of person(s) present at the subject address and what was said, (d) the identity of the owners of any cars in the driveway or other indications that defendant resides at the subject address; (e) in the proper circumstances, whether the technology actually belongs to the defendant and whether the defendant regularly uses or recently used the technology. Motions should include the attached form order for substituted service.

Judge Latosha Lewis PayneWARNING
Applies to
Motion for service by publication
Must include
proposed order

Motions for service by publication must comply with TRCP 109, 116, and 117, include an affidavit describing stated conditions, and use the form order.

Motions for service by publication must be in strict compliance with Texas Rule of Civil Procedure 109, 116 and 117. The motion should coordinates with an affidavit purposes (a) side of the steps trying to verify that the residence of of the defendant is unknown to the affiant and/or that the situation squads and the defendants are; or specific situation requires Horse; (b) attempts to locate the disclosure or the defendant is absent from or is a non-resident of the State; and (c) related to the nonresident, that the party has attempted to obtain personal service of any nonresidentalion the defendant as described at Rule 108 but has been able to do so do; may move on as included and the form order service of substitute.

Judge Latosha Lewis PayneWARNING
Applies to
Severance motion

A party seeking a severance must specifically list all pleadings to be transferred.

Severances: The party requesting the severance must specifically list all pleadings to be included in the severance order to be transferred to the new file.

Judge Latosha Lewis PayneWARNING
Applies to
Discovery motion

Discovery motions must identify every specific discovery response at issue, copying the responses as separate sub-documents or quoting them verbatim.

All discovery motions should specify each specific discovery response at issue and include a copy of the response(s) at issue as sub-documents when or state verbatim as a request and answer in the body of your motion.

Judge Latosha Lewis PayneWARNING
Applies to
Discovery motion
Must include
proposed order

Discovery proposed orders must list each discovery issue separately.

Proposed orders should list each discovery issue separately so that the court may sign an order granting or denying the requested relief.

Judge Latosha Lewis PayneWARNING
Applies to
Sanctions motion

Sanctions requests should only be made when a prior order has been violated by egregious conduct.

Sanctions should not be requested unless the opponent has violated a previous order and engaged in particularly egregious behavior.

Judge Latosha Lewis PayneWARNING
Applies to
Special setting request letter

A request for a special setting must be made by letter filed with the Court, served on all parties, stating alternative dates and deadline, with a courtesy copy to the Clerk.

In the event that you are unable to secure a hearing date as soon as necessary on the Court's regular oral hearing docket, or if you require a special setting, please file a letter with the Court, and serve it on all parties, requesting a special setting with alternative dates that are convenient for all parties and the date by which you are requesting the matter be heard by the Court. Please send a courtesy copy of the letter to the Clerk who will then give it to that judge for review.

Judge Latosha Lewis PayneWARNING
Applies to
Corporate withdrawal notice

For withdrawing from a corporate client, the notice must state the corporation cannot proceed pro se and after 30 days may face default or dismissal.

In addition to the items listed above, if the client is a corporation, the attorney must notify the client that the corporation cannot proceed pro se and that if the corporation has not obtained new counsel within 30 days a default judgment may be entered against it if a defendant, or its claims dismissed if a plaintiff.

Judge Latosha Lewis PayneWARNING
Applies to
Motion in limine

A motion in limine must be tailored to the specific case and not duplicate the standing order in limine.

Motions in Limine should be specific to the case. Do not duplicate items in your motions in limine. Our motion limited to only those items specific to the facts and circumstances in your case.

Judge Latosha Lewis PayneWARNING
Applies to
Agreed motion
Must include
certificate of conference

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.

Judge Lauren ReederWARNING
Applies to
Proposed continuance order

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.

Judge Lauren ReederWARNING
Applies to
Motion for continuance

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.

Judge Lauren ReederWARNING
Applies to
Proposed order

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.

Judge Lauren ReederWARNING
Applies to
Discovery proposed order

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.

Judge Lauren ReederWARNING
Applies to
Motion for default judgment

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.

Judge Lauren ReederWARNING
Applies to
Default judgment fee affidavit

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.

Judge Lauren ReederWARNING
Applies to
Motion

Motions and responses must identify specific deposition testimony rather than merely attaching depositions.

Motions and responses should identify specific deposition testimony relied upon to support a position, rather than simply attaching a deposition.

Judge Lee Kathryn ShuchartWARNING
Applies to
Proposed order

Proposed orders granting summary judgment must include all relief requested.

Proposed orders granting summary judgments should include all relief requested.

Judge Lee Kathryn ShuchartWARNING
Applies to
Motion

Motions must explain how damages are calculated and provide supporting evidence.

Motions should show how damages are calculated and provide supporting evidence.

Judge Lee Kathryn ShuchartWARNING
Applies to
Application for list inclusion

Attorneys seeking inclusion on the Court's guardian ad litem list must submit a written request with a complete resume detailing civil trial experience and confirm that professional liability coverage is in effect and will remain current.

Those wishing to be included in the Court's list must submit a written request with a complete resume that details the nature of the applicant's experience as a civil trial practitioner. Special capabilities, such as fluency in languages other than English, background in finance, and the like, also should be listed. Applicants also must confirm that professional liability coverage is in effect and will remain current.

Judge Sonya L. AstonWARNING
Applies to
Notice of oral hearing

After scheduling a hearing date with the clerk, parties must file a notice of oral hearing or, if applicable, a notice of written submission.

Once you have scheduled any hearing date with the court clerk, follow up with a notice of oral hearing or (if applicable) notice of written submission.

Judge Sonya L. AstonWARNING
Applies to
Agreed or unopposed motion

Agreed or unopposed motions need not be placed on the hearing or submission docket and must be titled as agreed or unopposed.

Agreed or unopposed motions do not have to be placed on the court's oral hearing or submission docket. All unopposed or agreed motions should be titled as such.

Judge Sonya L. AstonWARNING
Applies to
Agreed motion and order

Agreed motions and orders must include signature blocks for all agreeing parties and state 'AGREED AS TO SUBSTANCE AND FORM AND ENTRY REQUESTED.'

If a motion is actually agreed, the motion and order should contain signature blocks for all parties that are agreed to the relief requested, and should state "AGREED AS TO SUBSTANCE AND FORM AND ENTRY REQUESTED."

Judge Sonya L. AstonWARNING
Applies to
Certificate of conference

If the other side could not be reached before filing, the certificate of conference must describe the efforts to communicate and must be supplemented as soon as the parties actually confer.

If a party was unable to reach the other side prior to filing the motion, the certificate should state the efforts to communicate with that party, and should always be supplemented as soon as possible after the parties have actually confered. If the court does not see a supplemented certificate in such circumstances, please expect a call asking for one.

Judge Sonya L. AstonWARNING
Applies to
Certificate of conference

Certificates of conference must summarize reasonable efforts to confer; merely sending a motion, e-mail, or phone message does not constitute a conference.

Please summarize your reasonable efforts in your certificate. Note: sending a copy of a motion, without more, is not a conference. Sending an e-mail or leaving a telephone message, without more, is not a conference. If opposing counsel refuses to return numerous phone calls or other messages, describe your efforts to confer in your certificate of conference.

Judge Sonya L. AstonWARNING
Applies to
Rule 106 motion
Must include
proposed order

Rule 106 motions must be accompanied by the court's form order.

Any Rule 106 Motion should be accompanied by the court's form order.

Judge Sonya L. AstonWARNING
Applies to
Non suit dismissal or judgment

Non-suits, dismissals, and judgments must be titled interlocutory or final, and interlocutory orders must list which parties and claims are dismissed and which remain.

All non-suits, dismissals and judgments should be titled as interlocutory or final. Interlocutory orders should expressly list which parties and claims are being dismissed and which remain (if any).

Judge Sonya L. AstonWARNING
Applies to
Non suit motion notice or order

Non-suit motions, notices, and orders must expressly state they are filed pursuant to Rule 162 of the Texas Rules of Civil Procedure.

Motions and notices of non-suit as well as orders of non-suit should expressly state that they are being filed pursuant to Rule 162 of the Texas Rules of Civil Procedure.

Judge Sonya L. AstonWARNING
Applies to
Minor nonsuit or dismissal

Dismissals or nonsuits involving a minor's claim must inform the Court whether the minor is receiving a settlement so it can determine whether a guardian ad litem is needed.

If you are seeking to dismiss or nonsuit a minor's claim, the Court will want to know whether the minor is receiving a settlement to determine whether a guardian ad litem should be appointed.

Judge Sonya L. AstonWARNING
Applies to
Exhibit list

Accurate exhibit lists must be furnished to the judge and the court reporter.

Accurate exhibit lists should be furnished to Judge Hughes and to the court reporter.

Judge Sonya L. AstonWARNING
Applies to
Exhibit

Any exhibit that is offered, even if not admitted, must be tendered to the court reporter.

Once an exhibit is offered (even if not admitted), it must be tendered to the court reporter.

Judge Sonya L. AstonWARNING
Applies to
Deposition designation

Deposition page/line designations and a non-condensed transcript copy must be furnished to the court reporter before the deposition is offered.

Page/line designations of deposition testimony, along with a non-condensed copy of the transcript, are to be furnished to the court reporter prior to the offer.

Judge Sonya L. AstonWARNING
Applies to
Motion

Do not request a hearing in your motion.

Please do not request a hearing in your motion.

Judge Sonya L. AstonWARNING
Applies to
Motion for emergency hearing

If only one side thinks it is an emergency, file a motion for emergency hearing.

If only one side thinks it is an emergency, file a motion for emergency hearing.

Judge Sonya L. AstonWARNING
Applies to
Notice of hearing

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

The court has also established a permanent zoom link which should be put in notices of hearings and provided to parties/lawyers/witnesses who are part of the hearing - permanent zoom link.

Judge Tamika Craft-DemmingWARNING
Applies to
Ad litem fee form

Ad litems and other court appointees must complete the Texas Supreme Court form disclosing their fee amounts and who pays them.

The Texas Supreme Court has created a new form for ad litems (of all types) and other appointees to fill out regarding the amounts of their fees and by whom they are paid.

Judge Sonya L. AstonINFO
Applies to
Motion

Unopposed/agreed motions, non-suits, and motions for substitute service do not require setting a hearing.

Unopposed/agreed motions, non-suits, motions for substitute service do not require setting a hearing.

Judge Tamika Craft-DemmingINFO
Common questions about Harris County District Courts document filing requirements

What must be included with notice of hearing filings in Harris County District Courts?

The rule requires certificate of service. Opposed matters require scheduling a hearing and filing a notice of hearing with a certificate of service; otherwise the court will not rule.

View ruleSource: page 1, section SETTING A HEARING:

What must be included with exhibits filings in Harris County District Courts?

The rule identifies required filing content or certificates. Redaction of exhibits must be completed before arriving for trial.

View ruleSource: page 1, section EXHIBITS

What must be included with motion or other document requesting relief filings in Harris County District Courts?

The rule requires proposed order, certificate of service, and certificate of conference. Every motion or document asking the Court for relief must include a certificate of service, a certificate of conference (as required by TRCP), and a proposed order.

View ruleSource: page 1, section FILINGS AND COURTESY COPIES

What must be included with motion filings in Harris County District Courts?

The rule requires certificate of conference. Motions must include certificates of conference that explicitly describe the party's efforts to resolve the motion with all other parties before filing.

View ruleSource: page 1, section CERTIFICATES OF CONFERENCE

What must be included with discovery motion filings in Harris County District Courts?

The rule requires certificate of conference. Discovery motions and discovery hearing requests must contain a certificate that a reasonable effort to resolve the dispute was made and failed (TRCP 191.2).

View ruleSource: page 1, section CERTIFICATES OF CONFERENCE

What must be included with default judgment motion filings in Harris County District Courts?

The rule identifies required filing content or certificates. Default judgment motions must include a non-military affidavit obtained from the DMDC Military Verification service.

View ruleSource: page 1, section MOTIONS - Default Judgments